To amend the Internal Revenue Code of 1986 to reform the international tax system of the United States, and for other purposes.
Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,
SECTION 1. SHORT TITLE; AMENDMENT OF 1986 CODE; TABLE OF CONTENTS.
(a) Short Title.--This Act may be cited as the ``United States Job Creation and International Tax Reform Act of 2012''. (b) Amendment of 1986 Code.--Except as otherwise expressly provided, whenever in this Act an amendment or repeal is expressed in terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1986. (c) Table of Contents.--The table of contents of this Act is as follows:
Sec. 1. Short title; amendment of 1986 Code; table of contents. TITLE I--PARTICIPATION EXEMPTION SYSTEM FOR TAXATION OF FOREIGN INCOME
Sec. 101. Deduction for dividends received by domestic corporations from certain foreign corporations. Sec. 102. Application of dividends received deduction to certain sales and exchanges of stock. Sec. 103. Deduction for foreign intangible income derived from trade or business within the United States. Sec. 104. Treatment of deferred foreign income upon transition to participation exemption system of taxation. TITLE II--OTHER INTERNATIONAL TAX REFORMS
Subtitle A--Modifications of Subpart F
Sec. 201. Treatment of low-taxed foreign income as subpart F income. Sec. 202. Permanent extension of look-thru rule for controlled foreign corporations. Sec. 203....