To amend the Internal Revenue Code of 1986 to make permanent the look- through treatment of payments between related controlled foreign corporations.
Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,
SECTION 1. LOOK-THROUGH TREATMENT OF PAYMENTS BETWEEN RELATED CONTROLLED FOREIGN CORPORATIONS MADE PERMANENT.
(a) In General.--Subparagraph (C) of section 954(c)(6) of the Internal Revenue Code of 1986 is amended by striking ``and before January 1, 2012,''. (b) Effective Date.--The amendment made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2011, and to taxable years of United States shareholders with or within which such taxable years of foreign corporations end. <all>