Summary:
Protecting American Jobs and Exports Act - Amends the Export-Import Bank Act of 1945 to reauthorize the Export-Import Bank of the United States through FY2021.

Extends through FY2021 and gradually increases (with a specified exception) the Bank's aggregate outstanding loan, guarantee, and insurance authority.

Extends through FY2021 Bank authority to provide financing for the export of nonlethal defense articles or services whose primary end use will be for civilian purposes.

protecting american_jobs exports act_-_amends export-import_bank_act reauthorize export-import_bank united_states fy2021 extends fy2021 gradually increases specified exception bank aggregate outstanding loan guarantee insurance authority extends fy2021 bank authority provide financing export nonlethal defense articles services primary end use civilian purposes


Summary: Incentivizing Foreign Investment to Upgrade America's Infrastructure Act of 2014 - Amends the Internal Revenue Code to exempt a qualified foreign pension fund from taxation of gain or loss from, or tax withholding requirements on, the disposition of U.S. real property interests. Defines "qualified foreign pension fund" as any trust, corporation, or other organization or arrangement that: (1) is created or organized outside the United States; (2) is established to provide employee retirement or pension benefits; (3) does not have a single participant or beneficiary with a right to more than 5% of its assets; (4) is subject to regulation and tax reporting requirements in the country in which it is established or operates; and (5) is provided favorable tax treatment by the laws of the country in which it is established or operates.

incentivizing foreign investment upgrade america infrastructure act amends_the_internal_revenue_code exempt qualified foreign pension fund taxation gain loss tax withholding requirements disposition real property interests defines qualified foreign pension fund trust corporation organization arrangement created organized outside united_states established provide employee retirement pension benefits single participant beneficiary right assets subject regulation tax reporting requirements country established operates provided favorable tax treatment laws country established operates


Summary: Putting America First Corporate Tax Act - Amends the Internal Revenue Code to include in subpart F income (income of a controlled foreign corporation earned outside the United States that is not tax deferred): (1) a shareholder's pro rata share of the average of certain U.S. and foreign property held by a controlled foreign corporation as of the close of each quarter of a taxable year, and (2) the income of a controlled foreign corporation derived from any foreign country.

putting america corporate tax act amends_the_internal_revenue_code include subpart income income controlled foreign corporation earned outside united_states tax deferred shareholder pro rata share average certain foreign property held controlled foreign corporation close quarter taxable year income controlled foreign corporation derived foreign country


Summary: Real Estate Investment and Jobs Act of 2014 - Amends the Internal Revenue Code to: (1) increase from 5% to 10% the allowable ownership interest in real estate investment trust (REIT) stock for purposes of tax exemptions allowed by the Foreign Investment in Real Property Tax Act (FIRPTA) relating to foreign investment in U.S. real property interests; (2) require a U.S. real property holding corporation to make its status readily accessible and publicly available; (3) require brokers who sell an interest in a U.S. real property holding corporation to deduct and withhold 10% on the amount realized from the sale, with specified exceptions; (4) include regulated investment companies (RICs) and real estate investment companies (REITs) in the definition of U.S. real property interests; and (5) deny dividends derived from RICs and REITs a tax deduction for the U.S. source portion of dividends from certain foreign corporations.

real estate investment jobs_act amends_the_internal_revenue_code increase allowable ownership interest real estate investment trust reit stock purposes tax exemptions allowed foreign_investment_in_real_property_tax_act relating foreign investment real property interests require real property holding corporation status readily accessible publicly available require brokers sell interest real property holding corporation deduct withhold realized sale specified exceptions include regulated investment companies rics real estate investment companies reits definition real property interests deny dividends derived rics reits tax deduction source portion dividends certain foreign corporations


Summary: Pay What You Owe Before You Go Act - Amends the Internal Revenue Code to require the recapture in subpart F income (i.e., income of a controlled foreign corporation earned outside the United States which is not tax deferred) the accumulated deferred foreign income of such corporation (i.e., the undistributed earnings of the controlled foreign corporation over its undistributed U.S. earnings) for its last taxable year.

pay owe act amends_the_internal_revenue_code require recapture subpart income income controlled foreign corporation earned outside united_states tax deferred accumulated deferred foreign income corporation undistributed earnings controlled foreign corporation undistributed earnings taxable year


Summary:
Infrastructure and Global Tax Competitiveness Act of 2014 - Amends the Internal Revenue Code, with respect to the taxation of earnings and profits of a deferred foreign income corporation, to: (1) make such earnings and profit subject to taxation in the last taxable year prior to January 1, 2015, (2) reduce the rate of tax on such earnings and profits by allowing an exemption of 75%, and (3) allow such corporations to elect to pay such tax in eight installments.

Establishes the American Infrastructure Fund to provide assistance to states, local governments, and other public and private entities for investment in public infrastructure projects.

Appropriates tax revenues from this Act to the Highway Trust Fund.

Establishes the Highway Trust Fund Solvency Commission to propose recommendations and legislation for achieving long-term solvency of the Highway Trust Fund.

Establishes an 18-month deadline for the enactment of legislation that reforms the international tax system by eliminating the incentive to hold earnings in low-tax jurisdictions.

Sets forth provisions for the reform of the international tax system (to be effective if reform legislation is not enacted by the 18-month deadline established by this Act), including provisions relating to subpart F income and insurance income, gains and losses from the sale or exchange of stock in controlled foreign corporations, limitations on the foreign tax credit, and the tax treatment of previously deferred foreign income.

infrastructure global tax competitiveness act amends_the_internal_revenue_code respect taxation earnings profits deferred foreign income corporation earnings profit subject taxation taxable year prior january reduce rate tax earnings profits allowing exemption allow corporations elect pay tax installments establishes american infrastructure fund provide assistance states local governments public private entities investment public infrastructure projects appropriates tax revenues act highway_trust_fund establishes highway_trust_fund solvency commission propose recommendations legislation achieving long term solvency highway_trust_fund establishes month deadline enactment legislation reforms international tax system eliminating incentive hold earnings low tax jurisdictions sets forth provisions reform international tax system effective reform legislation enacted month deadline established act including provisions relating subpart income insurance income gains losses sale exchange stock controlled foreign corporations limitations foreign tax credit tax treatment previously deferred foreign income


Summary: Fair Tax for Repatriation Act - Declares that the federal tax on U.S. corporations earning profits abroad shall be a flat 5%. Makes the Department of the Treasury responsible for administering and enforcing such tax.

fair tax repatriation act declares federal tax corporations earning profits abroad shall flat makes department_of_the_treasury responsible administering enforcing tax


Summary: Corporate Tax Dodging Prevention Act - Amends the Internal Revenue Code, with respect to the taxation of the foreign-source income of domestic corporations, to: (1) eliminate the deferral of tax on the foreign-source income of U.S. corporations for taxable years beginning after December 31, 2013, (2) deny the foreign tax credit to large integrated oil companies that are dual capacity taxpayers, (3) limit the offset of the foreign tax credit to income that is subject to U.S. tax, and (4) treat foreign corporations managed and controlled in the United States as domestic corporations for U.S. tax purposes.

corporate tax prevention act amends_the_internal_revenue_code respect taxation foreign source income domestic corporations eliminate deferral tax foreign source income corporations taxable years beginning december deny foreign tax credit large integrated oil companies dual capacity taxpayers limit offset foreign tax credit income subject tax treat foreign corporations managed controlled united_states domestic corporations tax purposes


Summary: Offshoring Prevention Act - Amends the Internal Revenue Code to include in foreign base company income, for purposes of determining the foreign trade income of controlled foreign corporations, imported property income. Defines "imported property income" as, with certain exceptions, income attributable to property manufactured outside of the United States and imported for sale into the United States. Provides for a separate application of limitations on the foreign tax credit for imported property income.

prevention act amends_the_internal_revenue_code include foreign base company income purposes determining foreign trade income controlled foreign corporations imported property income defines imported property income certain exceptions income attributable property manufactured outside united_states imported sale united_states provides separate application limitations foreign tax credit imported property income


Summary:
Protect American Investments Act of 2013 - Prohibits a U.S.-based company, entity, or person from paying a financial transaction tax imposed by a foreign country on any covered financial transaction. Defines "covered financial transaction" as a financial transaction occurring on a U.S. exchange or over-the-counter within the United States, notwithstanding the nationality of the issuer of such security or the residence of any party to the transaction.

Requires the Secretary of the Treasury to: (1) promulgate regulations or other guidance to carry out this Act; (2) not assist any foreign government in collecting any excise tax, related penalty, or related judgment on any covered financial transaction; and (3) apply provisions of the Convention Between the United States of America and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income and Capital to exempt covered financial transactions.

protect american investments act prohibits company entity person paying financial transaction tax imposed foreign country covered financial transaction defines covered financial transaction financial transaction occurring exchange counter united_states notwithstanding nationality issuer security residence party transaction requires secretary treasury promulgate regulations guidance carry act assist foreign government collecting excise tax related penalty related judgment covered financial transaction apply provisions convention united_states_of_america government republic avoidance double taxation prevention fiscal evasion respect taxes income capital exempt covered financial transactions


Summary: Amends the Internal Revenue Code to treat United States cruise industry income as effectively connected with the conduct of a trade or business within the United States (thus subjecting such income to U.S. income taxation). Defines "United States cruise industry income" as income attributable to a voyage of a commercial passenger cruise vessel (a passenger vessel having berth or stateroom accommodations for at least 250 passengers) that extends over 1 or more nights and during which passengers embark or disembark the vessel in the United States. Prohibits any tax exemption or reduced tax rate under any U.S. treaty with respect to United States cruise industry income.

amends_the_internal_revenue_code treat united_states cruise industry income effectively connected conduct trade business united_states subjecting income income taxation defines united_states cruise industry income income attributable voyage commercial passenger cruise vessel passenger vessel having berth stateroom accommodations passengers extends passengers vessel united_states prohibits tax exemption reduced tax rate treaty respect united_states cruise industry income


Summary:
Stop Tax Haven Abuse Act - Authorizes the Secretary of the Treasury to impose restrictions on foreign jurisdictions or financial institutions operating in the United States that are of primary money laundering concern or that significantly impede U.S. tax enforcement.

Amends the Internal Revenue Code to:

 expand reporting requirements for U.S. persons who hold an interest in a passive foreign investment company; establish a rebuttable presumption against the validity of transactions by institutions that do not comply with reporting requirements under the Foreign Account Tax Compliance Act; treat certain foreign corporations managed and controlled primarily in the United States as domestic corporations for tax purposes; require tax withholding agents and financial institutions to report certain information about beneficial owners of foreign-owned financial accounts; treat swap payments sent offshore as taxable U.S. source income; and impose additional requirements for third party summonses used to obtain information in tax investigations that do not identify the person with respect to whose liability the summons is issued (i.e., John Doe summons). Amends the Securities Exchange Act of 1934 to: (1) require corporations registered with the Securities and Exchange Commission (SEC) to report annually, on a country-by country basis, on employees, gross revenues, payments made to governments, and other financial information; and (2) impose a fine for failure to disclose any holdings or transactions involving equity or debt instruments known to involve a foreign entity that would otherwise be subject to disclosure requirements.

Makes investment advisers and persons engaged in forming new business entities subject to anti-money laundering requirements.

Imposes new restrictions on U.S. corporations and other entities with foreign income with respect to: (1) tax deductions allocable to deferred foreign income, (2) the recalculation of foreign income taxes, (3) intangible property transferred overseas, (4) tax evasion activities by U.S. corporations reincorporating in a foreign country, and (5) loans to U.S. shareholders from controlled foreign corporations.

stop tax haven abuse act_-_authorizes secretary treasury impose restrictions foreign jurisdictions financial institutions operating united_states primary money laundering concern significantly impede tax enforcement amends_the_internal_revenue_code expand reporting requirements persons hold interest passive foreign investment company establish rebuttable presumption validity transactions institutions comply reporting requirements foreign account tax compliance act treat certain foreign corporations managed controlled primarily united_states domestic corporations tax purposes require tax withholding agents financial institutions report certain information beneficial owners foreign owned financial accounts treat swap payments sent offshore taxable source income impose additional requirements party summonses obtain information tax investigations identify person respect liability summons issued john_doe summons amends securities_exchange_act require corporations registered securities_and_exchange_commission sec report annually country country basis employees gross revenues payments governments financial information impose fine failure disclose holdings transactions involving equity debt instruments known involve foreign entity subject disclosure requirements makes investment advisers persons engaged forming new business entities subject anti money laundering requirements imposes new restrictions corporations entities foreign income respect tax deductions allocable deferred foreign income recalculation foreign income taxes intangible property transferred overseas tax evasion activities corporations foreign country loans shareholders controlled foreign corporations


Summary:
Keeping Jobs in America Act - Directs the Secretary of Commerce to establish a program to award grants to states that are recruiting high-value jobs (e.g., manufacturing, software publishing, and computer system design jobs that pay a higher than average wage). Allows the use of grants to issue forgivable loans to entities that employ not fewer than 50 full-time employees in high-value jobs and that are deciding whether to locate in rural and distressed areas.

Amends the Internal Revenue Code to: (1) grant business taxpayers a tax credit for up to 20% of insourcing expenses incurred for eliminating a business located outside the United States and  relocating it within the United States, and (2) deny a tax deduction for outsourcing expenses incurred in relocating a U.S. business outside the United States. Requires an increase in the taxpayer's employment of full-time employees in the United States in order to claim the tax credit for insourcing expenses.

Extends through 2017 the additional allowance for depreciation of business property (bonus depreciation) and the election to accelerate the alternative minimum tax credit in lieu of bonus depreciation. Makes permanent: (1) the increased $500,000 expensing allowance for depreciable business property and qualified real property, and (2) the new markets tax credit.

keeping jobs america act_-_directs secretary commerce establish program award grants states recruiting high value jobs manufacturing software publishing computer system design jobs pay higher average wage allows use grants issue loans entities employ fewer time employees high value jobs deciding locate rural distressed areas amends_the_internal_revenue_code grant business taxpayers tax credit insourcing expenses incurred eliminating business located outside united_states relocating united_states deny tax deduction outsourcing expenses incurred relocating business outside united_states requires increase taxpayer employment time employees united_states order claim tax credit insourcing expenses extends additional allowance depreciation business property bonus depreciation election accelerate alternative minimum tax credit lieu bonus depreciation makes permanent increased expensing allowance depreciable business property qualified real property new markets tax credit


Summary:
Stop Tax Haven Abuse Act

Authorizes the Secretary of the Treasury to impose restrictions on foreign jurisdictions or financial institutions operating in the United States that are of primary money laundering concern or that significantly impede U.S. tax enforcement.

Amends the Internal Revenue Code to:

 expand reporting requirements for U.S. persons who hold an interest in a passive foreign investment company; establish a rebuttable presumption against the validity of transactions by institutions that do not comply with reporting requirements under the Foreign Account Tax Compliance Act; treat certain foreign corporations managed and controlled primarily in the United States as domestic corporations for tax purposes; require tax withholding agents and financial institutions to report certain information about beneficial owners of foreign-owned financial accounts; treat swap payments sent offshore as taxable U.S. source income; and impose additional requirements for third party summonses used to obtain information in tax investigations that do not identify the person with respect to whose liability the summons is issued (i.e., John Doe summons). Amends the Securities Exchange Act of 1934 to: (1) require corporations registered with the Securities and Exchange Commission to report annually, on a country-by country basis, on employees, gross revenues, payments made to governments, and other financial information; and (2) impose a fine for failure to disclose any holdings or transactions involving equity or debt instruments known to involve a foreign entity that would otherwise be subject to disclosure requirements.

Makes investment advisers and persons engaged in forming new business entities subject to anti-money laundering requirements.

Imposes new restrictions on U.S. corporations and other entities with foreign income with respect to: (1) tax deductions allocable to deferred foreign income, (2) the recalculation of foreign income taxes, (3) intangible property transferred overseas, (4) tax evasion activities by U.S. corporations reincorporating in a foreign country, and (5) the interest expense tax deduction of certain subsidiaries of foreign corporations with excess domestic indebtedness.

Modifies rules for the taxation of inverted corporations (i.e., U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States) to provide that a foreign corporation that acquires the properties of a U.S. corporation or partnership after May 8, 2014, shall be treated as an inverted corporation and thus subject to U.S. taxation if, after such acquisition: (1) it holds more than 50% of the stock of the new entity (expanded affiliated group), or (2) the management or control of the new entity occurs primarily within the United States and the new entity has significant domestic business activities.

stop tax haven abuse act authorizes secretary treasury impose restrictions foreign jurisdictions financial institutions operating united_states primary money laundering concern significantly impede tax enforcement amends_the_internal_revenue_code expand reporting requirements persons hold interest passive foreign investment company establish rebuttable presumption validity transactions institutions comply reporting requirements foreign account tax compliance act treat certain foreign corporations managed controlled primarily united_states domestic corporations tax purposes require tax withholding agents financial institutions report certain information beneficial owners foreign owned financial accounts treat swap payments sent offshore taxable source income impose additional requirements party summonses obtain information tax investigations identify person respect liability summons issued john_doe summons amends securities_exchange_act require corporations registered securities_and_exchange_commission report annually country country basis employees gross revenues payments governments financial information impose fine failure disclose holdings transactions involving equity debt instruments known involve foreign entity subject disclosure requirements makes investment advisers persons engaged forming new business entities subject anti money laundering requirements imposes new restrictions corporations entities foreign income respect tax deductions allocable deferred foreign income recalculation foreign income taxes intangible property transferred overseas tax evasion activities corporations foreign country interest expense tax deduction certain subsidiaries foreign corporations excess domestic indebtedness modifies rules taxation inverted corporations corporations acquire foreign companies reincorporate foreign jurisdiction income tax rates lower united_states provide foreign corporation acquires properties corporation partnership shall treated inverted corporation subject taxation acquisition holds stock new entity expanded affiliated group management control new entity occurs primarily united_states new entity significant domestic business activities


Summary:
Offshoring Prevention Act

 Amends the Internal Revenue Code to include in foreign base company income, for purposes of determining the foreign trade income of controlled foreign corporations, imported property income. Defines "imported property income" as, with certain exceptions, income attributable to property manufactured outside of the United States and imported for sale into the United States. Provides for a separate application of limitations on the foreign tax credit for imported property income.


Summary:
Export-Import Bank Reform and Reauthorization Act of 2015

TITLE I--TAXPAYER PROTECTION PROVISIONS AND INCREASED ACCOUNTABILITY

(Sec. 101) This bill amends the Export-Import Bank Act of 1945 to set at $135 billion, for each of FY2015-FY2019, the authorized aggregate amount of loans, guarantees, and insurance the Export-Import Bank may have outstanding at any time.

If the rate at which borrowing entities are in default on a payment obligation (default rate) is 2% or more for a quarter, the Bank may not exceed the amount of loans, guarantees, and insurance outstanding on the last day of that quarter until the default rate becomes less than 2%.

(Sec. 102) The Bank shall build to and hold in reserve, to protect against future losses, at least 5% of its aggregate amount of disbursed and outstanding loans, guarantees, and insurance.

(Sec. 103) This bill amends the Export-Import Bank Reauthorization Act of 2012 (EIBRA) to require the Government Accountability Office's quadrennial review of the adequacy of the design and effectiveness of the Bank's fraud controls to include review of the Bank's compliance with these controls.

(Sec. 104) An Office of Ethics is established within the Bank to recommend administrative actions to establish or enforce standards of official conduct.

(Sec. 105) A Chief Risk Officer of the Bank is established to oversee all issues relating to risk within the Bank.

(Sec. 106) A Risk Management Committee is also established to:

 oversee periodic stress testing on the entire Bank portfolio and the monitoring of industry, geographic, and obligor exposure levels; and review all required reports on the Bank's default rate. (Sec. 107) The Bank's Inspector General shall conduct an audit or evaluation of the Bank's portfolio risk management procedures, including its implementation of the duties assigned to the Chief Risk Officer.

(Sec. 108) The Bank may establish a pilot program under which it may enter into contracts and other arrangements to share risks associated with its provision of guarantees, insurance, or credit, or participation in the extension of credit.

 The aggregate amount of liability the Bank may transfer through risk-sharing under a contract or other arrangement may not exceed $1 billion, nor a total of $10 billion during a fiscal year.

TITLE II--PROMOTION OF SMALL BUSINESS EXPORTS

(Sec. 201) This bill directs the Bank to:

 increase from 20% to 25% of its lending authority the amount made available to finance direct exports by small business concerns, and include in its annual report to Congress a report on its programs for U.S. businesses with less than $250 million in annual sales. TITLE III--MODERNIZATION OF OPERATIONS

(Sec. 301) This bill requires the Bank to implement policies to accept electronic payments and transaction documents.

(Sec. 302) The Bank's authority to use a portion of its surplus to update its information technology systems shall extend through FY2019.

TITLE IV--GENERAL PROVISIONS

(Sec. 401) The bill reauthorizes through FY2019 the Bank, the Sub-Saharan Africa Advisory Committee, and authority for dual use exports (of nonlethal defense articles or services primarily for civilian use).

(Sec. 402) The principal amounts of medium-term financing by the Bank shall be limited to $25 million.

The bill increases from a minimum of $10 million to a minimum of $25 million the amounts of:

 long-term loans or loan guarantees the Bank shall seek to ensure that U.S. insurance companies have a fair and open competitive opportunity to insure in connection with any transaction for which the loan or guarantee is provided, working capital export loans and guarantees to small businesses, and long-term support for projects to which certain procedures apply regarding the potential beneficial and adverse environmental effects of goods and services for which direct lending and guarantee support is requested. If the long-term support for projects subject to environmental effects consideration is less than $25 million, the minimum threshold shall be the one established pursuant to international agreements, including the Common Approaches for Officially Supported Export Credits and Environmental and Social Due Diligence, as adopted by the Organisation for Economic Co-operation and Development Council on June 28, 2012, and the risk-management framework ("Equator Principles") adopted by financial institutions for determining, assessing, and managing environmental and social risk in projects.

TITLE V--OTHER MATTERS

(Sec. 501) This bill prohibits the Bank from:

 denying an application for financing based solely on the industry, sector, or business that the application concerns; or promulgating or implementing policies that discriminate against an application based solely on the industry, sector, or business that the application concerns. These prohibitions apply only to applications for Bank financing for projects concerning the exploration, development, production, or export of energy sources and the generation or transmission of electrical power, or combined heat and power, regardless of the energy source involved.

(Sec. 502) The EIBRA is amended to require the President instead of the Department of the Treasury to initiate and pursue negotiations to end export credit financing.

The President shall propose to Congress a strategy to pursue with other major exporting countries, including Organisation for Economic Co-operation and Development (OECD) members and non-OECD members, to eliminate over a 10-year period subsidized export-financing programs, tied aid, export credits, and all other forms of government-supported export subsidies.

(Sec. 503) The Bank shall study the extent to which products it offers are available and used by companies that export information and communications technology services and related goods.

export-import_bank reform reauthorization act title taxpayer protection provisions increased accountability sec bill amends export-import_bank_act set billion fy2015-fy2019 authorized aggregate loans guarantees insurance export-import_bank outstanding time rate borrowing entities default payment obligation default rate quarter bank exceed loans guarantees insurance outstanding day quarter default rate sec bank shall build hold reserve protect future losses aggregate disbursed outstanding loans guarantees insurance sec bill amends export-import_bank reauthorization act require government_accountability_office quadrennial review adequacy design effectiveness bank fraud controls include review bank compliance controls sec office ethics established bank recommend administrative actions establish enforce standards official conduct sec chief risk officer bank established oversee issues relating risk bank sec risk management committee established oversee periodic stress testing entire bank portfolio monitoring industry geographic obligor exposure levels review required reports bank default rate sec bank inspector_general shall conduct audit evaluation bank portfolio risk management procedures including implementation duties assigned chief risk officer sec bank establish pilot program enter contracts arrangements share risks associated provision guarantees insurance credit participation extension credit aggregate liability bank transfer risk sharing contract arrangement exceed billion total billion fiscal year title promotion small business exports sec bill directs bank increase lending authority available finance direct exports small business concerns include annual report congress report programs businesses million annual sales title iii modernization operations sec bill requires bank implement policies accept electronic payments transaction documents sec bank authority use portion surplus update information technology systems shall extend fy2019 title general_provisions sec bill reauthorizes fy2019 bank sub saharan africa advisory_committee authority dual use exports nonlethal defense articles services primarily civilian use sec principal amounts medium term financing bank shall limited million bill increases minimum million minimum million amounts long term loans loan guarantees bank shall seek ensure insurance companies fair open competitive opportunity insure connection transaction loan guarantee provided working capital export loans guarantees small businesses long term support projects certain procedures apply potential beneficial adverse environmental effects goods services direct lending guarantee support requested long term support projects subject environmental effects consideration million minimum threshold shall established pursuant international agreements including common approaches officially supported export credits environmental social diligence adopted economic operation development council june risk management framework principles adopted financial institutions determining assessing managing environmental social risk projects title matters sec bill prohibits bank denying application financing based solely industry sector business application concerns promulgating implementing policies discriminate application based solely industry sector business application concerns prohibitions apply applications bank financing projects concerning exploration development production export energy sources generation transmission electrical power combined heat power regardless energy source involved sec amended require president instead department_of_the_treasury initiate pursue negotiations end export credit financing president shall propose congress strategy pursue major exporting countries including economic operation development members non members eliminate year period subsidized export financing programs tied aid export credits forms government supported export subsidies sec bank shall study extent products offers available companies export information communications technology services related goods


Summary:
Infrastructure 2.0 Act

Amends the Internal Revenue Code, with respect to the taxation of earnings and profits of a deferred foreign income corporation, to: (1) make such earnings and profit subject to taxation in the last taxable year that ends before the enactment of this Act; (2) reduce the rate of tax on such earnings and profits by allowing an exemption of 75% (equal to a tax of 8.75% of repatriated earnings and profits); and (3) allow such corporations to elect to pay such tax in eight installments.

Establishes the American Infrastructure Fund to provide assistance to states, local governments, and other public and private entities for investment in public infrastructure projects.

Appropriates tax revenues from this Act to the Highway Trust Fund.

Establishes the Highway Trust Fund Solvency Commission to submit recommendations and proposed legislation for achieving long-term solvency of the Highway Trust Fund. Sets forth congressional procedures for the expedited consideration of a bill containing such legislation.

Directs the Secretary of Transportation to establish a regional infrastructure accelerator pilot program to assist public entities in developing infrastructure projects.

Establishes a deadline of 18 months after the enactment of this Act for the enactment of legislation that reforms the international tax system by eliminating the incentive to hold earnings in low-tax jurisdictions. Imposes a tax on repatriated offshore corporate earnings upon the expiration of the deadline.

Sets forth provisions for the reform of the international tax system (to be effective if reform legislation is not enacted by the 18-month deadline established by this Act), including provisions relating to subpart F income and insurance income, gains and losses from the sale or exchange of stock in controlled foreign corporations, limitations on the foreign tax credit, and the tax treatment of previously deferred foreign income.

infrastructure act amends_the_internal_revenue_code respect taxation earnings profits deferred foreign income corporation earnings profit subject taxation taxable year ends enactment act reduce rate tax earnings profits allowing exemption equal tax repatriated earnings profits allow corporations elect pay tax installments establishes american infrastructure fund provide assistance states local governments public private entities investment public infrastructure projects appropriates tax revenues act highway_trust_fund establishes highway_trust_fund solvency commission submit recommendations proposed legislation achieving long term solvency highway_trust_fund sets forth congressional procedures expedited consideration bill containing legislation directs secretary transportation establish regional infrastructure accelerator pilot program assist public entities developing infrastructure projects establishes deadline months enactment act enactment legislation reforms international tax system eliminating incentive hold earnings low tax jurisdictions imposes tax repatriated offshore corporate earnings expiration deadline sets forth provisions reform international tax system effective reform legislation enacted month deadline established act including provisions relating subpart income insurance income gains losses sale exchange stock controlled foreign corporations limitations foreign tax credit tax treatment previously deferred foreign income


Summary:
Permanent Active Financing Exception Act of 2015

(Sec. 2) This bill amends the Internal Revenue Code to make permanent the subpart F foreign personal holding company income exemption for income that is derived in the active conduct of a banking, financing, or similar business, as a securities dealer, or in the conduct of an insurance business.

permanent active financing exception act sec bill amends_the_internal_revenue_code permanent subpart foreign personal holding company income exemption income derived active conduct banking financing similar business securities dealer conduct insurance business


Summary:
Promoting U.S. Jobs Through Exports Act of 2015

This bill amends the Export-Import Bank Act of 1945 to raise the cap on outstanding loans, guarantees, and insurance of the Export-Import Bank of the United States for FY2015-FY2022 and afterwards, subject to specified formulae.

The Bank, the Sub-Saharan Africa Advisory Committee, and authority for dual use exports (of nonlethal defense articles or services primarily for civilian use) are reauthorized through FY2022.

The Bank shall:

 provide technical assistance to small businesses on how to apply for financial assistance from the Bank; and study the extent to which Bank financial programs and products adequately meet the needs of small business concerns and enterprises that use, or seek to use, its medium-term programs to support the maintenance or creation of jobs in the United States through exports. The Bank shall also:

 conduct a comparative assessment of the practices of export credit agencies of other major providers of official export credit and member countries of the Organization for Economic Cooperation and Development (OECD) with respect to risk- or fee-sharing arrangements, in order to determine the extent to which the Bank could take steps to increase the share of loan-level risk borne by the private sector; and establish programs, if warranted, under which private financial institutions may share risk in the loans, guarantees, and other Bank products in exchange for receiving fees received from program participants. The fees to a private financial institution shall be commensurate with the level of risk taken by the institution. The Bank may enter into up to $25 billion worth of contracts of reinsurance, co-finance, or other risk-sharing arrangements on its portfolio or individual transactions with insurance companies, financial institutions, or export credit agencies.

The Bank shall develop a strategic plan to identify how most effectively to promote the export of goods and services related to renewable energy and end-use energy efficiency technology.

 The Bank President shall appoint a Chief Risk Officer to develop and manage a comprehensive process for identifying, assessing, monitoring, and reducing Bank-wide risk.

The Bank shall:

 report to specified congressional committees on its ethics programs, financial disclosure requirements, fraud detection training programs, conflicts of interest rules, and related matters; conduct a risk assessment of the vulnerability of its programs to employee misconduct and, if appropriate, issue updated supplemental standards of ethical conduct for Bank employees; and require all Bank directors, officers, and employees to certify annually that they have read, understood, complied with, and will continue to comply with, the Standards of Ethical Conduct for Employees of the Executive Branch. Requirements are prescribed or revised for enhanced Bank audit controls, an independent evaluation of the Bank portfolio, and an external review of fraud controls subject to the Export-Import Bank Reauthorization Act of 2012 (EIBRA).

The Bank must also perform (or cause to be performed) "risk-based Due Diligence," "Know Your Customer," and "Character Reputational Transaction Integrity" assessments of participants who benefit directly from Bank financing in structured finance and project finance transactions.

The Bank shall:

 develop a specific monitoring plan for each structured or project finance transaction before final Board of Directors approval that addresses the specific risks presented by the structure of the deal, and reserve the right to inspect any credit agreement for a transaction subject to Board approval sufficient to validate that disbursements comply with the law and Bank policies and procedures. The Bank shall also:

 implement policies to accept electronic documents in a manner that will not undermine any potential civil or criminal enforcement related to a transaction, assess its information technology infrastructure and use, and develop a clear and comprehensive information technology strategic plan meeting specified requirements. Information technology updating is reauthorized through FY2022.

The bill amends the EIBRA to direct the Department of the Treasury to initiate negotiations with non-OECD-member countries to bring them into a multilateral agreement establishing rules and limitations on officially supported export credits.

The U.S. Trade Representative shall seek to identify within the World Trade Organization (WTO) the extent to which countries that are not a party to the OECD Arrangement On Officially Supported Export Credits are also not in compliance with the terms of the Agreement on Subsidies and Countervailing Measures with respect to export finance, and seek appropriate WTO action for each one of them.

promoting jobs exports act bill amends export-import_bank_act raise cap outstanding loans guarantees insurance export-import_bank united_states fy2015 fy2022 subject specified formulae bank sub saharan africa advisory_committee authority dual use exports nonlethal defense articles services primarily civilian use reauthorized fy2022 bank shall provide technical assistance small businesses apply financial assistance bank study extent bank financial programs products adequately meet needs small business concerns enterprises use seek use medium term programs support maintenance creation jobs united_states exports bank shall conduct comparative assessment practices export credit agencies major providers official export credit member countries organization economic cooperation development respect fee sharing arrangements order determine extent bank steps increase share loan level risk borne private sector establish programs warranted private financial institutions share risk loans guarantees bank products exchange receiving fees received program participants fees private financial institution shall commensurate level risk taken institution bank enter billion worth contracts reinsurance finance risk sharing arrangements portfolio individual transactions insurance companies financial institutions export credit agencies bank shall develop strategic plan identify effectively promote export goods services related renewable energy end use energy efficiency technology bank president shall appoint chief risk officer develop manage comprehensive process identifying assessing monitoring reducing bank wide risk bank shall report specified congressional committees ethics programs financial disclosure requirements fraud detection training programs conflicts interest rules related matters conduct risk assessment vulnerability programs employee misconduct appropriate issue updated supplemental standards ethical conduct bank employees require bank directors officers employees certify annually read understood complied continue comply standards ethical conduct employees executive branch requirements prescribed revised enhanced bank audit controls independent evaluation bank portfolio external review fraud controls subject export-import_bank reauthorization act bank perform cause performed risk based diligence know customer character reputational transaction integrity assessments participants benefit directly bank financing structured finance project finance transactions bank shall develop specific monitoring plan structured project finance transaction final board_of_directors approval addresses specific risks presented structure deal reserve right inspect credit agreement transaction subject board approval sufficient validate disbursements comply law bank policies procedures bank shall implement policies accept electronic documents manner undermine potential civil criminal enforcement related transaction assess information technology infrastructure use develop clear comprehensive information technology strategic plan meeting specified requirements information technology updating reauthorized fy2022 bill amends direct department_of_the_treasury initiate negotiations non member countries bring multilateral agreement establishing rules limitations officially supported export credits trade representative shall seek identify world_trade_organization wto extent countries party arrangement officially supported export credits compliance terms agreement subsidies countervailing measures respect export finance seek appropriate wto action


Summary:
Permanent CFC Look-Through Act of 2015

(Sec. 2) This bill amends the Internal Revenue Code to make permanent the tax rule exempting dividends, interest, rents, and royalties received or accrued from certain controlled foreign corporations by a related entity from treatment as foreign holding company income (thus permitting tax deferral of such income).

permanent cfc look act sec bill amends_the_internal_revenue_code permanent tax rule exempting dividends interest rents royalties received accrued certain controlled foreign corporations related entity treatment foreign holding company income permitting tax deferral income


Summary:
Corporate Tax Dodging Prevention Act

 Amends the Internal Revenue Code, with respect to the taxation of the foreign-source income of domestic corporations, to:

 eliminate the deferral of tax on the foreign-source income of U.S. corporations for taxable years beginning after December 31, 2015; deny the foreign tax credit to large integrated oil companies that are dual capacity taxpayers; limit the offset of the foreign tax credit to income that is subject to U.S. tax; treat foreign corporations managed and controlled in the United States as domestic corporations for U.S. tax purposes; limit the tax deduction of the interest expense of a U.S. corporation that is a member of a financial reporting group (i.e., a group that prepares consolidated financial statements according to generally accepted accounting principles or international financial reporting standards); and revise rules for the taxation of inverted corporations (i.e., U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States) to provide that a foreign corporation that acquires the properties of a U.S. corporation or partnership after May 8, 2014, shall be treated as an inverted corporation and thus subject to U.S. taxation if, after such acquisition it holds more than 50% of the stock of the new entity (expanded affiliated group).

corporate tax prevention act amends_the_internal_revenue_code respect taxation foreign source income domestic corporations eliminate deferral tax foreign source income corporations taxable years beginning december deny foreign tax credit large integrated oil companies dual capacity taxpayers limit offset foreign tax credit income subject tax treat foreign corporations managed controlled united_states domestic corporations tax purposes limit tax deduction interest expense corporation member financial reporting group group prepares consolidated financial statements according generally accepted accounting principles international financial reporting standards revise rules taxation inverted corporations corporations acquire foreign companies reincorporate foreign jurisdiction income tax rates lower united_states provide foreign corporation acquires properties corporation partnership shall treated inverted corporation subject taxation acquisition holds stock new entity expanded affiliated group


Summary: Amends the Internal Revenue Code, with respect to the tax on nonresident alien individuals, to: (1) make permanent the tax exemption for interest-related dividends and short-term capital gain dividends received from a regulated investment company, and (2) expand the categories of interest-related dividends for which a tax exemption is allowed.

amends_the_internal_revenue_code respect tax nonresident alien individuals permanent tax exemption interest related dividends short term capital gain dividends received regulated investment company expand categories interest related dividends tax exemption allowed


Summary:
Real Estate Investment and Jobs Act of 2015

This bill amends the Internal Revenue Code to increase from 5% to 10% the stock ownership threshold in a real estate investment trust for purposes of exempting proceeds from dispositions of such stock from withholding requirements under the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA). Exempts from FIRPTA withholding requirements U.S. real property interests held by: (1) a qualified foreign pension fund created or organized outside the United States, or (2) any entity all of the interests of which are held by a qualified foreign pension fund.

real estate investment jobs_act bill amends_the_internal_revenue_code increase stock ownership threshold real estate investment trust purposes exempting proceeds dispositions stock withholding requirements foreign_investment_in_real_property_tax_act exempts withholding requirements real property interests held qualified foreign pension fund created organized outside united_states entity interests held qualified foreign pension fund


Summary:
Foreign Manufacturers Legal Accountability Act of 2015

 Expresses the sense of Congress with respect to jurisdiction of courts in the United States over foreign manufacturers that import products into the United States.

Directs the Food and Drug Administration (FDA) (with respect to drugs, devices, cosmetics, and biological products), the Consumer Product Safety Commission (with respect to consumer products), and the Environmental Protection Agency (with respect to chemical substances, new chemical substances, and pesticides) to require foreign manufacturers and producers of such products (or components used to manufacture them), in excess of a minimum value or quantity, to establish a registered agent in the United States authorized to accept service of process on their behalf for the purpose of any state or federal regulatory proceeding or civil action in state or federal court.

Deems a foreign manufacturer or producer of products covered under this Act that registers an agent to consent to the personal jurisdiction of the state or federal courts of the state in which the agent is located for the purpose of any civil or regulatory proceeding.

Requires any person who imports into the United States a covered product manufactured or produced outside the United States to provide to the U.S. Customs and Border Protection (CBP) a declaration that to the best of the person's knowledge, with respect to the importation of each covered product, the foreign manufacturer or producer of the product has registered an agent in the United States. Directs the CBP Commissioner to prescribe related regulations.

Subjects an importer who fails to provide or files a false declaration to certain penalties. Requires the Department of Agriculture and the FDA jointly to study the feasibility and advisability of requiring foreign producers of food distributed in commerce to establish a registered agent in the United States who is authorized to accept service of process on behalf of such producers for the purpose of all civil and regulatory actions in state and federal courts.

Requires the head of each agency cited in this Act similarly to study feasible and advisable methods of requiring foreign manufacturers or producers of component parts of covered products distributed in U.S. commerce to establish registered agents in the United States for purposes of such service of process.

foreign manufacturers legal accountability_act expresses sense congress respect jurisdiction courts united_states foreign manufacturers import products united_states directs food_and_drug_administration fda respect drugs devices cosmetics biological products consumer_product_safety_commission respect consumer products environmental_protection_agency respect chemical substances new chemical substances pesticides require foreign manufacturers producers products components manufacture excess minimum value quantity establish registered agent united_states authorized accept service process behalf purpose state federal regulatory proceeding civil action state federal court deems foreign manufacturer producer products covered act registers agent consent personal jurisdiction state federal courts state agent located purpose civil regulatory proceeding requires person imports united_states covered product manufactured produced outside united_states provide customs border_protection cbp declaration best person knowledge respect importation covered product foreign manufacturer producer product registered agent united_states directs cbp commissioner prescribe related regulations subjects importer fails provide files false declaration certain penalties requires department_of_agriculture fda jointly study feasibility advisability requiring foreign producers food distributed commerce establish registered agent united_states authorized accept service process behalf producers purpose civil regulatory actions state federal courts requires head agency cited act similarly study feasible advisable methods requiring foreign manufacturers producers component parts covered products distributed commerce establish registered agents united_states purposes service process


Summary:
Aviation Screening Contractor Reform and Accountability Act

This bill prohibits subsidiaries of foreign-owned companies from performing security screening at commercial airports and establishes additional requirements for private screening companies.

The Transportation Security Administration (TSA) must not:

 contract with private screening companies that are U.S. subsidiaries of foreign companies or have compromised covert security testing, permit the screening to be performed by a subcontractor, or provide funding to any company that provides screening services at an airport in excess of the required amount. Private screening companies must:

 provide the right of first refusal to federal or private sector employees who are performing screening at an airport when a contract is awarded; and report to the TSA regarding security breaches, retention rates of employees, adverse employment actions, and customer complaints. The TSA must use Government Accountability Office (GAO) guidance to compare the costs of overseeing private companies with using federal employees for screening, enhance monitoring of the performance of private screening companies, and require companies to train employees on handling sensitive information.

Each airport must notify passengers if screening is conducted by a contractor and provide contact information for reporting complaints.

The GAO must conduct annual covert testing of airports that use private screening companies.

The TSA must establish a process for confidentially reporting deficiencies, waste, or vulnerabilities with respect to private screening services. The companies must not retaliate against individuals who report this information, refuse to engage in illegal activities, or testify during government proceedings.

aviation screening contractor reform accountability_act bill prohibits subsidiaries foreign owned companies performing security screening commercial airports establishes additional requirements private screening companies transportation_security_administration tsa contract private screening companies subsidiaries foreign companies compromised covert security testing permit screening performed subcontractor provide funding company provides screening services airport excess required private screening companies provide right refusal federal private sector employees performing screening airport contract awarded report tsa security breaches retention rates employees adverse employment actions customer complaints tsa use government_accountability_office gao guidance compare costs overseeing private companies federal employees screening enhance monitoring performance private screening companies require companies train employees handling sensitive information airport notify passengers screening conducted contractor provide contact information reporting complaints gao conduct annual covert testing airports use private screening companies tsa establish process confidentially reporting deficiencies waste vulnerabilities respect private screening services companies retaliate individuals report information refuse engage illegal activities testify government proceedings


Summary:
Stop Outsourcing and Create American Jobs Act of 2015

This bill directs the Department of the Treasury to develop and publish a list of countries that are tax havens for corporations.

The bill amends the Internal Revenue Code to increase the penalties on corporations for: (1) underpayment of tax involving an undisclosed foreign financial asset located in a tax haven country; (2) reportable transaction understatements involving transactions in a tax haven country; and (3) fraud, tax evasion, or false statements involving transactions in a tax haven country.

The bill: (1) grants a preference in the award of federal contracts to contractors who have not engaged in outsourcing, and (2) defines "outsourcing" as the laying off of a U.S. worker from a job and the hiring or contracting for the same job to be performed in a foreign country.

Revenues generated by this Act must be set aside for the reduction of the public debt.

stop outsourcing create american_jobs act bill directs department_of_the_treasury develop publish list countries tax havens corporations bill amends_the_internal_revenue_code increase penalties corporations underpayment tax involving undisclosed foreign financial asset located tax haven country reportable transaction understatements involving transactions tax haven country fraud tax evasion false statements involving transactions tax haven country bill grants preference award federal contracts contractors engaged outsourcing defines outsourcing laying worker job hiring contracting job performed foreign country revenues generated act set aside reduction public debt


Summary:
Putting America First Corporate Tax Act

This bill amends the Internal Revenue Code to modify the definition of subpart F income (i.e., income of a controlled foreign corporation earned outside the United States that is not tax-deferred) to include income of a controlled foreign corporation derived from any foreign country. This modification is applicable to taxable years beginning after December 31, 2015.

putting america corporate tax act bill amends_the_internal_revenue_code modify definition subpart income income controlled foreign corporation earned outside united_states tax deferred include income controlled foreign corporation derived foreign country modification applicable taxable years beginning december


Summary:
This bill expressly prohibits the Department of the Treasury from collecting from a U.S. person or transmitting to any foreign jurisdiction any country-by-country report (CbCR) information of any U.S. person for taxable years beginning before January 1, 2017. CbCR information is used by the Organization for Economic Cooperation and Development to develop its Base Erosion and Profit Shifting (BEPS) Action Plan to increase the transparency of transfer pricing practices and other tax transactions of multinational business enterprises.

Treasury must: (1) suspend the transmittal of CbCR information of any U.S. person to a foreign jurisdiction if it determines that such jurisdiction is abusing BEPS master file documentation requirements or failing to safeguard the confidentiality of information required in the master file, and (2) report to the congressional tax committees on allegations or reports received concerning the abuse of master file documentation requirements and any actions taken with respect to such allegations.

bill expressly prohibits department_of_the_treasury collecting person transmitting foreign jurisdiction country country report information person taxable years beginning january information organization economic cooperation development develop base erosion profit action plan increase transparency transfer pricing practices tax transactions multinational business enterprises treasury suspend transmittal information person foreign jurisdiction determines jurisdiction master file documentation requirements failing safeguard confidentiality information required master file report congressional tax committees allegations reports received concerning abuse master file documentation requirements actions taken respect allegations


Summary:
EB-5 Integrity Act of 2016

This bill amends the Immigration and Nationality Act to revise the EB-5 (alien investor) regional center program.

A regional center shall operate within a defined geographic area, and shall be consistent with the purpose of concentrating pooled investment within such area.

The bill prescribes job creation requirements.

 Alien investor capital may not be used to purchase municipal or any other publicly-available bonds.

Approved regional centers must give advance notice to the Department of Homeland Security (DHS) of significant proposed changes to their organizational structure, ownership, or administration, which must then be approved by DHS.

A commercial enterprise associated with a regional center shall file an application with, and obtain approval from, DHS for each investment offering to aliens seeking alien investor classification.

 Approval of a business plan shall be binding on future adjudication except in cases of fraud, criminal misuse, public or national security, or major errors of law or fact.

The bill expands regional center annual statement reporting requirements.

The bill also prohibits regional center involvement for persons who have committed certain crimes, human trafficking, controlled substance trafficking, espionage, or terrorist activity. DHS shall suspend or terminate designation of any regional center, or the participation of any new commercial enterprise or job-creating entity, that knowingly involved such a person.

Only a U.S. national or lawfully admitted permanent resident may be involved with a regional center.

A regional center shall monitor and supervise all offers, purchases, and sales of securities made by associated parties to ensure compliance with U.S. securities laws.

The bill establishes the EB-5 Integrity Fund in the Treasury, and prescribes specified fees to be collected from each regional center.

 Direct and third party promoters must: (1) comply with DHS rules and standards and federal or state securities laws, (2) register with U.S. Citizenship and Immigration Services, and (3) meet other specified requirements.

 The bill prescribes fund source and gift restrictions.

DHS shall deny or revoke the approval of a business plan application with any investment or business arrangement that: (1) presents a threat to public safety or national security; or (2) presents a significant risk of criminal misuse, fraud, or abuse.

An alien investor shall demonstrate that the required capital and any administrative funds were obtained from a lawful source and through lawful means.

If a regional center or regional center associated commercial enterprise has its designation or participation terminated for reasons relating to fraud or other specified offenses, any associated person, including an alien investor, who was a knowing participant shall be permanently barred from future program participation.

DHS employees may not give specified preferential treatment to any organization or individual in connection with any aspect of the EB-5 regional center investor visa program.

eb-5 integrity act bill amends immigration_and_nationality_act revise eb-5 alien investor regional center program regional center shall operate defined geographic area shall consistent purpose concentrating pooled investment area bill prescribes job creation requirements alien investor capital purchase municipal publicly available bonds approved regional centers advance notice department_of_homeland_security dhs significant proposed changes organizational structure ownership administration approved dhs commercial enterprise associated regional center shall file application obtain approval dhs investment offering aliens seeking alien investor classification approval business plan shall binding future adjudication cases fraud criminal misuse public national security major errors law fact bill expands regional center annual statement reporting requirements bill prohibits regional center involvement persons committed certain crimes human trafficking controlled substance trafficking espionage terrorist activity dhs shall suspend terminate designation regional center participation new commercial enterprise job creating entity knowingly involved person national lawfully admitted permanent resident involved regional center regional center shall monitor supervise offers purchases sales securities associated parties ensure compliance securities laws bill establishes eb-5 integrity fund treasury prescribes specified fees collected regional center direct party promoters comply dhs rules standards federal state securities laws register citizenship_and_immigration_services meet specified requirements bill prescribes fund source gift restrictions dhs shall deny revoke approval business plan application investment business arrangement presents threat public safety national security presents significant risk criminal misuse fraud abuse alien investor shall demonstrate required capital administrative funds obtained lawful source lawful means regional center regional center associated commercial enterprise designation participation terminated reasons relating fraud specified offenses associated person including alien investor knowing participant shall permanently barred future program participation dhs employees specified preferential treatment organization individual connection aspect eb-5 regional center investor visa program


Summary:
United States Call Center Worker and Consumer Protection Act of 2016

This bill requires a business that employs 50 or more call center employees, excluding part-time employees, or 50 or more call center employees who in the aggregate work at least 1,500 hours per week, exclusive of overtime, to notify the Department of Labor at least 120 days before relocating such center outside of the United States. Violators are subject to a civil penalty of up to $10,000 per day.

Labor must make publicly available a list of all such employers that relocate a call center. It may remove from the list an employer that has relocated the call center from a location outside the United States to a location inside the United States.

Employers must remain on the list for up to three years after each relocation. An employer is ineligible for federal grants or federal guaranteed loans for five years after being added to the list, except where the employer demonstrates that a lack of such loan or grant would threaten national security, result in substantial job loss in the United States, or harm the environment. Federal or state executive agencies or military departments, when awarding a civilian or defense-related contract, must give preference to a U.S. employer that does not appear on the list.

Businesses that initiate or receive a customer service communication must require each of their employees or agents participating in the communication to disclose their physical location at the beginning of each such communication unless all involved employees or agents are located in the United States. The bill exempts any communication: (1) initiated by a consumer if the consumer knows or reasonably should know that the employee or agent is located outside the United States, or (2) related to the provision of emergency services. Upon request, businesses must transfer a customer to a customer service agent who is physically located in the United States.

The Federal Trade Commission (FTC) may exclude certain classes or types of business entities or customer service communications from the requirements of this Act under exceptionally compelling circumstances. The bill sets forth authority for the FTC to enforce against violations.

united_states center worker consumer protection act bill requires business employs center employees excluding time employees center employees aggregate work hours week exclusive overtime notify department_of_labor days relocating center outside united_states violators subject civil penalty day labor publicly available list employers relocate center remove list employer relocated center location outside united_states location inside united_states employers remain list years relocation employer ineligible federal grants federal guaranteed loans years added list employer demonstrates lack loan grant threaten national security result substantial job loss united_states harm environment federal state executive agencies military departments awarding civilian defense related contract preference employer appear list businesses initiate receive customer service communication require employees agents participating communication disclose physical location beginning communication involved employees agents located united_states bill exempts communication initiated consumer consumer knows reasonably know employee agent located outside united_states related provision emergency services request businesses transfer customer customer service agent physically located united_states federal_trade_commission ftc exclude certain classes types business entities customer service communications requirements act exceptionally compelling circumstances bill sets forth authority ftc enforce violations


Summary: This bill amends the Internal Revenue Code, with respect to the tax on nonresident alien individuals, to expand the categories of interest-related dividends for which a tax exemption is allowed.

bill amends_the_internal_revenue_code respect tax nonresident alien individuals expand categories interest related dividends tax exemption allowed


Summary:
Foreign Business Bribery Prohibition Act of 2016

This bill amends the Foreign Corrupt Practices Act of 1977 (FCPA) to authorize private rights of action against persons that violate the FCPA's anti-bribery provisions, which prohibit giving things of value to foreign officials or political parties for purposes of obtaining or retaining business. A person that violates the FCPA's anti-bribery provisions shall be liable for up to treble damages to a securities issuer, domestic business concern, or U.S. person damaged by the violation.

A plaintiff must prove an FCPA anti-bribery violation by the defendant that: (1) prevented the plaintiff from obtaining or retaining business, and (2) assisted the defendant in obtaining or retaining such business.

foreign business bribery prohibition act bill amends foreign corrupt practices act authorize private rights action persons violate anti bribery provisions prohibit giving things value foreign officials political parties purposes obtaining retaining business person violates anti bribery provisions shall liable treble damages securities issuer domestic business concern person damaged violation plaintiff prove anti bribery violation defendant prevented plaintiff obtaining retaining business assisted defendant obtaining retaining business


Summary:
American Job Creation and Investment Promotion Reform Act of 2016

This bill amends the Immigration and Nationality Act to revise EB-5 (alien immigrant investor) provisions, including regional center program provisions.

The bill prescribes E-B5 requirements regarding: (1) fund sources; (2) threats to the national interest; and (3) fraud, misrepresentation,and criminal misuse.

Future program participation is barred for a person who knowingly participated in conduct that caused a program center's termination.

The EB-5 regional center program is extended through September 30, 2021.

EB-5 investors must be at least 18 years old.

The bill: (1) provides initial conditional permanent resident status for an alien investor (and the investor's spouse and children), and (2) sets aside 2,000 EB-5 visas for aliens who invest in rural areas and 2,000 EB-5 visas for aliens who invest in priority urban investment areas.

A regional center shall operate within a defined geographic area and shall be consistent with the purpose of concentrating pooled investment within such area.

The bill prescribes job creation requirements.

Approved regional centers must give advance notice to the Department of Homeland Security (DHS) of significant proposed changes to their organizational structure, ownership, or administration.

U.S. nationals are included in the minimum of 10 U.S. persons for whom an EB-5 project must provide employment.

Only a U.S. national or lawfully admitted permanent resident may be involved with a regional center.

A regional center shall monitor and supervise all offers, purchases, and sales of securities made by associated parties to ensure compliance with U.S. securities laws.

The bill establishes the EB-5 Integrity Fund.

The bill prescribes fund source and gift restrictions.

Minimum investment amounts are increased.

The bill authorizes concurrent filing of EB-5 petitions and applications for adjustment to conditional lawful permanent resident status.

american job creation investment promotion reform_act bill amends immigration_and_nationality_act revise eb-5 alien immigrant investor provisions including regional center program provisions bill prescribes requirements fund sources threats national interest fraud misrepresentation criminal misuse future program participation barred person knowingly participated conduct caused program center termination eb-5 regional center program extended september eb-5 investors years old bill provides initial conditional permanent resident status alien investor investor spouse children sets aside eb-5 visas aliens invest rural areas eb-5 visas aliens invest priority urban investment areas regional center shall operate defined geographic area shall consistent purpose concentrating pooled investment area bill prescribes job creation requirements approved regional centers advance notice department_of_homeland_security dhs significant proposed changes organizational structure ownership administration nationals included minimum persons eb-5 project provide employment national lawfully admitted permanent resident involved regional center regional center shall monitor supervise offers purchases sales securities associated parties ensure compliance securities laws bill establishes eb-5 integrity fund bill prescribes fund source gift restrictions minimum investment amounts increased bill authorizes concurrent filing eb-5 petitions applications adjustment conditional lawful permanent resident status


Summary: This bill amends the Internal Revenue Code to exempt premiums paid on non-cash-value property and casualty insurance policies from taxes to enforce reporting on certain foreign accounts.

bill amends_the_internal_revenue_code exempt premiums paid non cash value property casualty insurance policies taxes enforce reporting certain foreign accounts


Summary:
Offshoring Prevention Act

 Amends the Internal Revenue Code to include in foreign base company income, for purposes of determining the foreign trade income of controlled foreign corporations, imported property income. Defines "imported property income" as, with certain exceptions, income attributable to property manufactured outside of the United States and imported for sale into the United States. Provides for a separate application of limitations on the foreign tax credit for imported property income.

prevention act amends_the_internal_revenue_code include foreign base company income purposes determining foreign trade income controlled foreign corporations imported property income defines imported property income certain exceptions income attributable property manufactured outside united_states imported sale united_states provides separate application limitations foreign tax credit imported property income


Summary:
Stop Tax Haven Abuse Act

Authorizes the Secretary of the Treasury to impose restrictions on foreign jurisdictions or financial institutions operating in the United States that are of primary money laundering concern or that significantly impede U.S. tax enforcement.

Amends the Internal Revenue Code to:

 expand reporting requirements for U.S. persons who hold an interest in a passive foreign investment company; establish a rebuttable presumption against the validity of transactions by institutions that do not comply with reporting requirements under the Foreign Account Tax Compliance Act; treat certain foreign corporations managed and controlled primarily in the United States as domestic corporations for tax purposes; require tax withholding agents and financial institutions to report certain information about beneficial owners of foreign-owned financial accounts; treat swap payments sent offshore as taxable U.S. source income; and impose additional requirements for third party summonses used to obtain information in tax investigations that do not identify the person with respect to whose liability the summons is issued (i.e., John Doe summons). Amends the Securities Exchange Act of 1934 to: (1) require corporations registered with the Securities and Exchange Commission to report annually, on a country-by country basis, on employees, gross revenues, payments made to governments, and other financial information; and (2) impose a fine for failure to disclose any holdings or transactions involving equity or debt instruments known to involve a foreign entity that would otherwise be subject to disclosure requirements.

Makes investment advisers and persons engaged in forming new business entities subject to anti-money laundering requirements.

Imposes new restrictions on U.S. corporations and other entities with foreign income with respect to: (1) tax deductions allocable to deferred foreign income, (2) the recalculation of foreign income taxes, (3) intangible property transferred overseas, (4) tax evasion activities by U.S. corporations reincorporating in a foreign country, and (5) the interest expense tax deduction of certain subsidiaries of foreign corporations with excess domestic indebtedness.

Modifies rules for the taxation of inverted corporations (i.e., U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States) to provide that a foreign corporation that acquires the properties of a U.S. corporation or partnership after May 8, 2014, shall be treated as an inverted corporation and thus subject to U.S. taxation if, after such acquisition: (1) it holds more than 50% of the stock of the new entity (expanded affiliated group), or (2) the management or control of the new entity occurs primarily within the United States and the new entity has significant domestic business activities.

stop tax haven abuse act authorizes secretary treasury impose restrictions foreign jurisdictions financial institutions operating united_states primary money laundering concern significantly impede tax enforcement amends_the_internal_revenue_code expand reporting requirements persons hold interest passive foreign investment company establish rebuttable presumption validity transactions institutions comply reporting requirements foreign account tax compliance act treat certain foreign corporations managed controlled primarily united_states domestic corporations tax purposes require tax withholding agents financial institutions report certain information beneficial owners foreign owned financial accounts treat swap payments sent offshore taxable source income impose additional requirements party summonses obtain information tax investigations identify person respect liability summons issued john_doe summons amends securities_exchange_act require corporations registered securities_and_exchange_commission report annually country country basis employees gross revenues payments governments financial information impose fine failure disclose holdings transactions involving equity debt instruments known involve foreign entity subject disclosure requirements makes investment advisers persons engaged forming new business entities subject anti money laundering requirements imposes new restrictions corporations entities foreign income respect tax deductions allocable deferred foreign income recalculation foreign income taxes intangible property transferred overseas tax evasion activities corporations foreign country interest expense tax deduction certain subsidiaries foreign corporations excess domestic indebtedness modifies rules taxation inverted corporations corporations acquire foreign companies reincorporate foreign jurisdiction income tax rates lower united_states provide foreign corporation acquires properties corporation partnership shall treated inverted corporation subject taxation acquisition holds stock new entity expanded affiliated group management control new entity occurs primarily united_states new entity significant domestic business activities


Summary:
American Job Creation and Investment Promotion Reform Act of 2015

This bill amends the Immigration and Nationality Act to extend the EB-5 regional center program through September 30, 2020.

A regional center shall operate within a defined geographic area, and shall be consistent with the purpose of concentrating pooled investment and creating a significant economic impact within such area.

Up to 90% of the employment creation requirements for an EB-5 visa regional center investor (alien investor) may be satisfied through indirect job creation.

Job creation credit based on capital investment by non-alien entrepreneurs is limited.

Approved regional centers must give advance notice to the Department of Homeland Security (DHS) of significant proposed changes to their organizational structure, ownership, or administration, which must then be approved by DHS.

A commercial enterprise associated with a regional center shall file an application with, and obtain approval from, DHS for each investment offering to aliens seeking alien investor classification, which shall include: (1) a comprehensive business plan, (2) an economic analysis of estimated job creation, and (3) documents filed with the Securities and Exchange Commission.

For a capital investment in a designated targeted employment area, at least 50% of the estimated job creation shall be expected to occur within a combined statistical area or a metropolitan statistical area, or if the targeted employment area is outside of such an area, in any county that is included in or adjacent to the targeted employment area.

DHS shall deny or revoke the approval of a business plan application with any investment or business arrangement that: (1) presents a threat to public safety or national security; or (2) presents a significant risk of criminal misuse, fraud, or abuse.

DHS shall establish a process for premium processing of business plan applications.

Sanctions are provided for a regional center or affiliated individual that has violated any certification requirement or that is conducting itself in a manner inconsistent with its designation.

A regional center shall be terminated from program participation for specified violations.

A regional center shall monitor and supervise all offers, purchases, and sales of securities made by associated parties to ensure compliance with U.S. securities laws.

The EB-5 Integrity Fund is established in the Treasury. An annual $20,000 fee shall be collected from each regional center.

An alien investor shall demonstrate that the required capital and any administrative funds were obtained from a lawful source and through lawful means.

If a regional center or regional center associated commercial enterprise has its designation or participation terminated for reasons relating to fraud, intentional material misrepresentation, criminal misuse, or threats to public safety or national security, any person associated with that regional center, including an alien investor, shall be permanently barred from future program participation if the person was a knowing participant in the conduct that led to the termination.

An alien entrepreneur who has invested the requisite capital for at least 24 months before admission shall obtain the status of an alien lawfully admitted for permanent residence without a conditional basis upon approval of the required petition.

If DHS determines that the approval of any petition or the conditional permanent resident status granted to an alien entrepreneur is contrary to the U.S. national interest for reasons of fraud, misrepresentation, criminal misuse, or threats to public safety or national security, DHS shall notify the alien of that determination and deny the petition or terminate the permanent resident status of the alien and family members.

 The number of fiscal year EB-5 (employment creation) visas is increased for qualified immigrants who invest in a new commercial enterprise which, in addition to creating jobs in a targeted employment area, will invest the required capital in such area.

Designation of a non-targeted unemployment area as a targeted employment area shall be valid for renewable two-year periods.

The minimum investment amounts are increased for non-targeted employment areas and targeted employment areas.

The child of an alien investor whose conditional permanent resident status is terminated shall continue to be considered a child of the alien investor for purposes of a subsequent immigrant petition by the alien investor if the child remains unmarried and the alien investor's subsequent petition is filed within one year after termination of status.

Concurrent filing of EB-5 petitions and applications is authorized for status adjustment to conditional lawful permanent resident.

An alien petitioning for classification as an alien investor may file a petition with DHS only after approval of an investment in a commercial enterprise.

The U.S. Citizenship and Immigration Service shall set fees for services at a level sufficient to ensure the full recovery of the costs of providing those services, including the cost of ensuring that adjudication is completed not later than:

 120 days for a regional center, 120 days after receiving an application for approval of investment in a commercial enterprise, 150 days after receiving a petition from an alien desiring to be classified as an alien investor, and 180 days after receiving a petition from an alien for removal of conditional permanent resident status. DHS employees may not give specified preferential treatment to any organization or individual in connection with any aspect of the EB-5 regional center investor visa program.

american job creation investment promotion reform_act bill amends immigration_and_nationality_act extend eb-5 regional center program september regional center shall operate defined geographic area shall consistent purpose concentrating pooled investment creating significant economic impact area employment creation requirements eb-5 visa regional center investor alien investor satisfied indirect job creation job creation credit based capital investment non alien entrepreneurs limited approved regional centers advance notice department_of_homeland_security dhs significant proposed changes organizational structure ownership administration approved dhs commercial enterprise associated regional center shall file application obtain approval dhs investment offering aliens seeking alien investor classification shall include comprehensive business plan economic analysis estimated job creation documents filed securities_and_exchange_commission capital investment designated targeted employment area estimated job creation shall expected occur combined statistical area metropolitan_statistical_area targeted employment area outside area county included adjacent targeted employment area dhs shall deny revoke approval business plan application investment business arrangement presents threat public safety national security presents significant risk criminal misuse fraud abuse dhs shall establish process premium processing business plan applications sanctions provided regional center affiliated individual violated certification requirement conducting manner inconsistent designation regional center shall terminated program participation specified violations regional center shall monitor supervise offers purchases sales securities associated parties ensure compliance securities laws eb-5 integrity fund established treasury annual fee shall collected regional center alien investor shall demonstrate required capital administrative funds obtained lawful source lawful means regional center regional center associated commercial enterprise designation participation terminated reasons relating fraud intentional material misrepresentation criminal misuse threats public safety national security person associated regional center including alien investor shall permanently barred future program participation person knowing participant conduct led termination alien entrepreneur invested requisite capital months admission shall obtain status alien lawfully admitted permanent residence conditional basis approval required petition dhs determines approval petition conditional permanent resident status granted alien entrepreneur contrary national interest reasons fraud misrepresentation criminal misuse threats public safety national security dhs shall notify alien determination deny petition terminate permanent resident status alien family members number fiscal year eb-5 employment creation visas increased qualified immigrants invest new commercial enterprise addition creating jobs targeted employment area invest required capital area designation non targeted unemployment area targeted employment area shall valid renewable year periods minimum investment amounts increased non targeted employment areas targeted employment areas child alien investor conditional permanent resident status terminated shall continue considered child alien investor purposes subsequent immigrant petition alien investor child remains unmarried alien investor subsequent petition filed year termination status concurrent filing eb-5 petitions applications authorized status adjustment conditional lawful permanent resident alien petitioning classification alien investor file petition dhs approval investment commercial enterprise citizenship immigration service shall set fees services level sufficient ensure recovery costs providing services including cost ensuring adjudication completed later days regional center days receiving application approval investment commercial enterprise days receiving petition alien desiring classified alien investor days receiving petition alien removal conditional permanent resident status dhs employees specified preferential treatment organization individual connection aspect eb-5 regional center investor visa program


Summary:
EB-5 Integrity Act of 2015

This bill amends the Immigration and Nationality Act to revise the EB-5 (alien investor) regional center program.

A regional center shall operate within a defined geographic area, and shall be consistent with the purpose of concentrating pooled investment within such area.

The bill prescribes job creation requirements.

 Alien investor capital may not be used to purchase municipal or any other publicly-available bonds.

Approved regional centers must give advance notice to the Department of Homeland Security (DHS) of significant proposed changes to their organizational structure, ownership, or administration, which must then be approved by DHS.

A commercial enterprise associated with a regional center shall file an application with, and obtain approval from, DHS for each investment offering to aliens seeking alien investor classification.

 Approval of a business plan shall be binding on future adjudication except in cases of fraud, criminal misuse, public or national security, or major errors of law or fact.

The bill expands regional center annual statement reporting requirements.

The bill also prohibits regional center involvement for persons who have committed certain crimes, human trafficking, controlled substance trafficking, espionage, or terrorist activity. DHS shall suspend or terminate designation of any regional center, or the participation of any new commercial enterprise or job-creating entity, that knowingly involved such a person.

Only a U.S. national or lawfully admitted permanent resident may be involved with a regional center.

A regional center shall monitor and supervise all offers, purchases, and sales of securities made by associated parties to ensure compliance with U.S. securities laws.

The bill establishes the EB-5 Integrity Fund in the Treasury, and prescribes specified fees to be collected from each regional center.

 Direct and third party promoters must: (1) comply with DHS rules and standards and federal or state securities laws, (2) register with U.S. Citizenship and Immigration Services, and (3) meet other specified requirements.

 The bill prescribes fund source and gift restrictions.

DHS shall deny or revoke the approval of a business plan application with any investment or business arrangement that: (1) presents a threat to public safety or national security; or (2) presents a significant risk of criminal misuse, fraud, or abuse.

An alien investor shall demonstrate that the required capital and any administrative funds were obtained from a lawful source and through lawful means.

If a regional center or regional center associated commercial enterprise has its designation or participation terminated for reasons relating to fraud or other specified offenses, any associated person, including an alien investor, who was a knowing participant shall be permanently barred from future program participation.

DHS employees may not give specified preferential treatment to any organization or individual in connection with any aspect of the EB-5 regional center investor visa program.


Summary:
Corporate Inverters Earnings Stripping Reform Act of 2016

This bill amends the Internal Revenue Code to impose limitations on the tax deduction for interest paid by corporations which are designated as applicable entities (i.e., members of an expanded affiliated group which includes a surrogate foreign corporation which is not treated as a domestic corporation). Such an entity may not claim a tax deduction for interest that exceeds 25% of its adjusted taxable income and may not carry forward interest which is paid or accrued during the first year in which such entity becomes an applicable entity.

The bill requires an applicable entity to file an annual application for an approval agreement (i.e., a prefiling, advance pricing, or other agreement involving a related-party transaction) with the Internal Revenue Service during the 10-year period after it becomes an applicable entity.

corporate earnings reform_act bill amends_the_internal_revenue_code impose limitations tax deduction interest paid corporations designated applicable entities members expanded affiliated group includes surrogate foreign corporation treated domestic corporation entity claim tax deduction interest exceeds adjusted taxable income carry forward interest paid accrued year entity applicable entity bill requires applicable entity file annual application approval agreement prefiling advance pricing agreement involving related party transaction internal_revenue_service year period applicable entity