A bill to 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.

Read twice and referred to the Committee on Finance.

Congressional Research Service

Official summary

Version 00 · Introduced in Senate · Nov 16, 2007

Amends Internal Revenue Code provisions relating to taxation of U.S. shareholders of controlled foreign corporations to: (1) exclude from foreign personal holding company income rents and royalties attributable to computer software that is leased or licensed for use outside the United States and that was developed or marketed by a controlled 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 exemption from foreign personal holding company income for active financing income (income from insurance, banking, financing, or similar businesses) earned on business operations overseas.

Read the summary on Congress.gov

PlainBill analysis is coming later. This page presents official source data. We have not yet published a PlainBill explanation for this bill.

People & committees

Who introduced it

Sen. Smith, Gordon H. [R-OR] · R–OR

Committees

Finance Committee

1 cosponsorship records, including any withdrawals

Sen. Cantwell, Maria [D-WA]

Legislative record

Actions

A procedural vote is different from passage. Passage in one chamber does not establish enactment. Explore the glossary.

Nov 16, 2007
Read twice and referred to the Committee on Finance.
Nov 16, 2007
Introduced in Senate

Primary sources

Bill text & related measures

Text links open the official source. We currently store references to these documents.

Introduced in Senate · Nov 16, 2007 Formatted Text PDF Formatted XML

Related bills identified by Congress.gov

No related bills are listed in this snapshot. This does not establish whether the proposal has appeared in earlier Congresses.

Source last updated: Jan 14, 2025. Consult Congress.gov for the current record.

AI Conversation Starters

Explore the bill from different angles

Choose a perspective, copy a prompt, and paste it into your preferred AI. Each prompt includes the bill version and available official source links, and asks for counterarguments as well as supporting evidence.

Neutral evidence review

Objective

Analyze S.2380 as objectively as possible. Explain its main provisions, who would be affected, possible benefits and harms, implementation, exceptions, and uncertainties. Present the strongest arguments for and against it, and identify evidence needed to assess its public impact.

View full prompt & sources

Discuss S.2380, 110th Congress: A bill to 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.

Official record: https://www.congress.gov/bill/110th-congress/senate-bill/2380

Text version to examine: Introduced in Senate · 2007-11-16.

Official full text: https://www.congress.gov/110/bills/s2380/BILLS-110s2380is.htm

Imported record last updated by the source: 2025-01-14T19:05:57Z. Verify current status and distinguish any later version from the version above.

Read the official text before answering. If you cannot access it, say so and ask me to provide it; do not assume a link means you have read the document. Distinguish proposals from enacted law, cite sources, and separate facts, interpretation, and uncertain predictions. Include counterarguments even when using a particular perspective.

Analyze S.2380 as objectively as possible. Explain its main provisions, who would be affected, possible benefits and harms, implementation, exceptions, and uncertainties. Present the strongest arguments for and against it, and identify evidence needed to assess its public impact.

Fairness and public impact

Progressive lens

Examine S.2380 through a progressive lens, focusing on fairness, access, economic inequality, and effects on vulnerable communities. Explain potential benefits, costs, and unintended consequences. Consider the strongest counterarguments and distinguish stated goals from demonstrated outcomes.

View full prompt & sources

Discuss S.2380, 110th Congress: A bill to 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.

Official record: https://www.congress.gov/bill/110th-congress/senate-bill/2380

Text version to examine: Introduced in Senate · 2007-11-16.

Official full text: https://www.congress.gov/110/bills/s2380/BILLS-110s2380is.htm

Imported record last updated by the source: 2025-01-14T19:05:57Z. Verify current status and distinguish any later version from the version above.

Read the official text before answering. If you cannot access it, say so and ask me to provide it; do not assume a link means you have read the document. Distinguish proposals from enacted law, cite sources, and separate facts, interpretation, and uncertain predictions. Include counterarguments even when using a particular perspective.

Examine S.2380 through a progressive lens, focusing on fairness, access, economic inequality, and effects on vulnerable communities. Explain potential benefits, costs, and unintended consequences. Consider the strongest counterarguments and distinguish stated goals from demonstrated outcomes.

Institutions and government scope

Conservative lens

Examine S.2380 through a conservative lens, focusing on fiscal responsibility, institutional stability, federalism, and the scope of government. Explain potential benefits, costs, and unintended consequences. Consider the strongest counterarguments and any provisions that challenge this perspective.

View full prompt & sources

Discuss S.2380, 110th Congress: A bill to 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.

Official record: https://www.congress.gov/bill/110th-congress/senate-bill/2380

Text version to examine: Introduced in Senate · 2007-11-16.

Official full text: https://www.congress.gov/110/bills/s2380/BILLS-110s2380is.htm

Imported record last updated by the source: 2025-01-14T19:05:57Z. Verify current status and distinguish any later version from the version above.

Read the official text before answering. If you cannot access it, say so and ask me to provide it; do not assume a link means you have read the document. Distinguish proposals from enacted law, cite sources, and separate facts, interpretation, and uncertain predictions. Include counterarguments even when using a particular perspective.

Examine S.2380 through a conservative lens, focusing on fiscal responsibility, institutional stability, federalism, and the scope of government. Explain potential benefits, costs, and unintended consequences. Consider the strongest counterarguments and any provisions that challenge this perspective.

Individual rights and government power

Liberty lens

Examine S.2380 through a civil-liberties and limited-government lens. Consider individual rights, privacy, voluntary choice, accountability, and government power. Explain tradeoffs, possible safeguards, and the strongest counterarguments without assuming the proposal is beneficial or harmful.

View full prompt & sources

Discuss S.2380, 110th Congress: A bill to 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.

Official record: https://www.congress.gov/bill/110th-congress/senate-bill/2380

Text version to examine: Introduced in Senate · 2007-11-16.

Official full text: https://www.congress.gov/110/bills/s2380/BILLS-110s2380is.htm

Imported record last updated by the source: 2025-01-14T19:05:57Z. Verify current status and distinguish any later version from the version above.

Read the official text before answering. If you cannot access it, say so and ask me to provide it; do not assume a link means you have read the document. Distinguish proposals from enacted law, cite sources, and separate facts, interpretation, and uncertain predictions. Include counterarguments even when using a particular perspective.

Examine S.2380 through a civil-liberties and limited-government lens. Consider individual rights, privacy, voluntary choice, accountability, and government power. Explain tradeoffs, possible safeguards, and the strongest counterarguments without assuming the proposal is beneficial or harmful.