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H.R. 459, To amend the Internal Revenue Code of 1986 to deny the foreign tax credit and the benefits of deferral to companies doing business directly or through subsidiaries in Sudan until the Government of Sudan takes demonstrable steps to end genocide in Sudan (1 comment ↓)
H.R. 459 would amend the Internal Revenue Code of 1986 to deny the foreign tax credit and the benefits of deferral to companies doing business directly or through subsidiaries in Sudan until the Government of Sudan takes demonstrable steps to end genocide in Sudan.
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Martin B. Tittle - mbt@martintittle.com
H.R. 459 effects its purpose by adding a new subparagraph (C) to Internal Revenue Code (IRC) Sec. 901(j)(2). That new subparagraph would subject Sudan to the strictures of IRC Sec. 901(j)(1). However, it appears Sudan is already subject to 901(j)(1), and has been since Feb. 12, 1994. See IRS Revenue Ruling 2005-3, 2005-1 C.B. 334. Therefore, it is unclear what real world change would occur if H.R.459 were enacted. Inquiries to Congressman Rangel's office by the tax press regarding this issue have, as of Feb. 1, gone unanswered.