S. 2380 would amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions.

== Detailed Summary ==

<summary>
(Log inAmends Internal Revenue Code provisions relating to edit the wikitaxation of U.S. shareholders of controlled foreign corporations to: (1) exclude from foreign personal holding company income rents and be the firstroyalties attributable to providecomputer software that is leased or licensed for use outside the United States and that was developed or marketed by a detailed summarycontrolled foreign corporation or related person; (2) increase to $5 million (currently, $1 million) the de minimis dollar amount for determinations of foreign base company income; (3) permanently extend the look-thru rule for for the tax treatment of income received or accrued from a controlled foreign corporation; and (4) permanently extend the bill!)exemption from foreign personal holding company income for active financing income (income from insurance, banking, financing, or similar businesses) earned on business operations overseas.
</summary>

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== Status of the Legislation ==

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(Log inLatest Major Action: 11/16/2007: Referred to edit the wikiSenate committee. Status: Read twice and be the firstreferred to update the status of the bill!)Committee on Finance.
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== Points in Favor ==

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== Points Against ==

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