H.R. 5793: Close Foreign Tax Loopholes: Make it in America Act of 2010

111th Congress · introduced 2010-07-20 · Taxation · Latest: Referred to the House Committee on Ways and Means.

federal

Follow this bill, step by step

Where it came from: introduced 2010-07-20 · official record
Who proposed it: Rep. Garamendi, John [D-CA-10] · what a sponsor is
What happened next: no floor votes in our records yet. Why?
Where it stands now: Referred to the House Committee on Ways and Means. Not final yet: this can still change. We check for updates every day.
If it becomes law and spends money: follow the money to money laws, then agencies and contracts and grants.

What does this mean?

Official title

Close Foreign Tax Loopholes: Make it in America Act of 2010

Plain summary

Close Foreign Tax Loopholes: Make it in America Act of 2010 - Amends the Internal Revenue Code, with respect to the taxation of foreign income and the foreign tax credit, to: (1) suspend the recognition of foreign tax credits until the related foreign income is taken into account for U.S. tax purposes; (2) deny a foreign tax credit for foreign income not subject to U.S. taxation due to a covered asset acquisition (defined as an acquisition that results in an increase in tax basis for U.S. tax purposes but not for foreign tax purposes); (3) apply a separate foreign tax credit limitation for each item of income that would be treated as derived from sources within the United States and that would be treated as arising from sources outside the United States under a treaty obligation (if the taxpayer chooses the benefits of such treaty); (4) limit the amount of foreign tax credits that may be claimed by a U.S. domestic corporation with respect to a deemed dividend paid by a foreign subsidiary; (5) prevent a reduction in earnings in profits of a foreign corporation in an acquisition if more than 50% of the dividends arising from such acquisition would not be subject to U.S. taxation or would be includible in the earnings and profits of a controlled foreign corporation; (6) treat a foreign corporation as a member of an affiliated group for interest allocation and apportionment purposes if more than 50% of its gross income is effectively connected with a U.S. trade or business and at least 80% of either the vote or value of its outstanding stock is owned directly or indirectly by members of the affiliated group; (7) repeal tax rules exempting foreign source income attributable to the active conduct of a foreign trade or business from withholding of tax requirements; (8) treat as income received in the United States amounts received from noncorporate residents or domestic corporations with respect to guarantees and amounts paid by any foreign person if such amounts are connected with income that is effectively connected with the conduct of a trade or business in the United States; and (9) provide that the statute of limitations for assessing any tax on certain foreign transactions shall apply only to items related to a failure to provide information to the Internal Revenue Service (IRS) due to reasonable cause and not willful neglect.

Congressional Research Service summary (Introduced in House), quoted unchanged (nonpartisan). Read the source.

What a vote does

A “Yea” vote

If it passes both chambers and is signed, it becomes law.

A “Nay” vote

If it is not passed, current law stays as it is.

PSI Sci description of the legislative step (not an opinion).

What does this mean? (plain words)

Official text

Close Foreign Tax Loopholes: Make it in America Act of 2010

Source: Congressional Research Service summary (Introduced in House)

AI explanation – may be wrong, check the official text

No AI explanation yet. It takes up to a minute to write and is then saved for everyone.

Limited to a few requests an hour per person.

The strongest published arguments

Arguments for (supporters)

Needs sources: no published arguments on this side yet. We only show items backed by a published source. Suggest one.

Arguments against (opponents)

Needs sources: no published arguments on this side yet. We only show items backed by a published source. Suggest one.

Alternatives

Needs sources: no published alternatives yet (for example a different bill, a law instead of an amendment, or keeping current law). We only show items backed by a published source. Suggest one.

How did my representative vote? · This bill's floor votes

Officials and money

Sponsor: Rep. Garamendi, John [D-CA-10] · 18 cosponsors

Cost estimate: No cost estimate published yet.

Cosponsors on this site

Marcy Kaptur (D-OH), Frank Pallone, Jr. (D-NJ), Martin Heinrich (D-NM), Tammy Baldwin (D-WI)

Sponsor's campaign money: Rep. Garamendi, John [D-CA-10] reported raising $582,746 (2025–2026). Details. Shown for context only; it does not mean any donor supported this bill.

No linked floor roll calls in our collected records yet. This does not mean the bill has never had a vote. Check the official bill history.

Words on this page, explained (3)

Obligation: A binding promise by a government agency to pay money, for example by signing a contract or awarding a grant. Spending data such as USAspending.gov counts money when it is obligated, which can be before it is actually paid out.
Rulemaking: The process agencies use to write regulations that carry out laws passed by Congress or a legislature. Usually an agency publishes a proposed rule, takes public comments, then publishes a final rule.
Statute: A written law passed by a legislature. A statute can be changed by a later law; changing a constitution needs an amendment.

Plain meanings written from linked sources. All words.

Sources

Congressional Research Service summary (Introduced in House)
Congress.gov
Data: GovInfo BILLSTATUS bulk data (Library of Congress), BILLSTATUS-111hr5793.xml <https://www.govinfo.gov/bulkdata/BILLSTATUS/111/hr>

Record fed-us-cong111-hr5793 · catalog fed-us-congress-bills-cong111 · updated 2026-11-15 by psicol fed-bills-cong111