Johnson Introduces International Tax Simplification Act of 2006

Rep. Sam Johnson (R-TX), a senior member of the House Ways & Means Committee, today introduced the International Tax Simplification Act of 2006, which would make a number changes to various international tax rules:

• Permanent Subpart F exemption for active financing income
• Permanent look-thru rule for related controlled foreign corporations
• Repeal of foreign base company sales and services income rules
• Repeal of foreign base company oil related income rules
• Repeal of special rules for applying foreign tax credit in case of foreign oil and gas income
• Extension of carryforward period for excess foreign taxes
• Subpart F earnings and profits determined under generally accepted accounting principles
• Acceleration of election to allocate interest on a worldwide basis
• Expansion of de minimis rule under subpart F