legislation: 97-hr-7311
Data license: Public Domain (U.S. Government data) · Data source: Federal Register API & Regulations.gov API
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| 97-hr-7311 | 97 | hr | 7311 | International Sales and Services Corporation Tax Act of 1982 | Taxation | 1982-11-29 | 1982-11-29 | Referred to House Committee on Ways and Means. | House | Rep. Frenzel, Bill [R-MN-3] | MN | R | F000380 | 1 | International Sales and Services Corporation Tax Act of 1982 - Amends the Internal Revenue Code to repeal the tax deferral provisions relating to Domestic International Sales Corporation (DISC) and to allow U.S. corporations or citizens to establish an International Sales and Services Corporation (ISSC) in lieu of a DISC. Allows the transfer of assets from an existing DISC to an ISSC. Sets forth rules for such transfers. Provides that, for qualification as an ISSC, a corporation must: (1) have 95 percent or more of its gross receipts as qualified trading receipts; (2) have 95 percent or more of all assets as qualified trading assets; (3) have only one class of stock and have outstanding stock with a par or stated value of at least $2,500; (4) have a taxable year which is the same as that of any of its principal shareholders; (5) maintain a duplicate set of records and books in the United States; and (6) make an election to be treated as an ISSC. Defines "qualified export assets" and "qualified export receipts" for purposes of this Act. Makes ineligible for ISSC treatment any corporation which is: (1) incorporated in any State or Puerto Rico; (2) incorporated in a country which does not generally impose an income or similar tax; (3) a personal holding company; or (4) a member of a controlled group which includes a DISC. Sets forth inter-company pricing rules in the case of the sale of trading property to an ISSC by a person subject to allocation of income rules. Sets forth rules for the taxation of income to shareholders. Sets forth rules for the treatment of gains on the disposition of stock in an ISSC. Allows a foreign tax credit to shareholders of an ISSC for a proportionate share of taxes paid by an ISSC to a foreign country. Sets forth rules for the allocation of income to shareholders in the case of an actual distribution. | 2025-08-29T19:50:12Z |