Come Home, Corporate America, Act of 1995

Come Home, Corporate America, Act of 1995 - Amends the Internal Revenue Code to terminate the foreign tax credit. Allows the deduction of foreign taxes for which the credit is made unallowable by this Act. (Sec. 3) Directs the Secretary of the Treasury to prescribe regulations regarding allocation of income and deductions which use a formulaic approach to clearly reflect income of multinational corporations. (Sec. 4) Treats the gain or loss of a nonresident alien individual or foreign corporation that is a ten-percent shareholder in a domestic corporation upon disposition of such a corporation's stock as if the taxpayer were engaged during the taxable year in a trade or business within the United States and as if such gain or loss were attributable to a permanent U.S. trade or business establishment. Treats such gain or loss as from sources within the United States, notwithstanding source rules for personal property sales. Imposes a 26-percent minimum tax on nonresident alien individuals. Treats as stock, for purposes of these provisions, options or other rights to acquire a domestic corporation's stock, conversion features of debt instruments, and other interests in a domestic corporation other than those solely as a creditor. Treats as a dividend attributable to a domestic corporation's stock any gain which would be subject to tax but for a treaty and which results from a distribution in liquidation or redemption. Provides for the withholding of tax on such dispositions. Penalizes, and treats as tax evasion, the failure to pay the tax established by this Act where amounts were not deducted and withheld. Excepts such gain from the branch profits tax imposed on foreign corporations. Requires notice to the Secretary upon distributions by a U.S. person to a foreign person in redemption of stock or complete liquidation of a subsidiary. (Sec. 5) Removes the exemption of ten-percent shareholders from the tax on interest of nonresident alien individuals received from portfolio debt investments. Redefines portfolio interest as only interest paid on obligations issued by governmental entities. (Sec. 6) Terminates, effective with taxable years beginning January 1, 1996, the exclusion of foreign earned income and the housing cost amounts of U.S. citizens or residents living abroad. (Sec. 7) Terminates, effective with taxable years beginning January 1, 1996, the exclusion from gross income of exempt foreign trade income of foreign sales corporations. (Sec. 8) Revises rules for the determination of the income of controlled foreign corporations. Repeals provisions which reduce the controlled foreign corporation income of export trade corporations. (Sec. 9) Allows the Secretary to extend for an additional three years the limitation period for assessment of a foreign-related deficiency if the deficiency cannot be accurately assessed before the expiration of the usual three-year period because of delay or other taxpayer actions which prevented timely assessment of the deficiency. Defines a foreign-related deficiency as one: (1) of a 25-percent foreign-owned domestic corporation to the extent the deficiency is attributable to a transaction with a related party who is a foreign person; and (2) of a foreign corporation with respect to the tax on income for foreign corporations connected with U.S. business or the branch profits tax. (Sec. 10) Reduces from $75 billion to $37.5 billion the aggregate loan, guarantee, and insurance authority of the Export-Import Bank of the United States. Requires the Bank to charge and collect a fee (based on credit risk and not less than a fee that would be charged for a similar arms-length transaction in the private sector) for the provision of a guarantee, insurance, extension of credit, or for its participation in an extension of credit. (Sec. 11) Abolishes the Overseas Private Investment Corporation and transfers its functions relating to obligations effective on October 1, 1995, to the Department of State. Terminates all such remaining obligations when they expire.