United States HR 2985: To amend the Internal Revenue Code of 1986 to clarify that payment of taxes on deferred foreign income in installments shall not prevent credit or refund of overpayments or increase estimated taxes.

Bill Text

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116TH CONGRESS
1ST SESSION H. R. 2985
To amend the Internal Revenue Code of 1986 to clarify that payment of
taxes on deferred foreign income in installments shall not prevent credit
or refund of overpayments or increase estimated taxes.
IN THE HOUSE OF REPRESENTATIVES
MAY 23, 2019
Mr. ESTES (for himself and Mr. SCHNEIDER) introduced the following bill;
which was referred to the Committee on Ways and Means
A BILL
To amend the Internal Revenue Code of 1986 to clarify
that payment of taxes on deferred foreign income in
installments shall not prevent credit or refund of over-
payments or increase estimated taxes.
Be it enacted by the Senate and House of Representa-1
tives of the United States of America in Congress assembled, 2
SECTION 1. INSTALLMENTS NOT TO PREVENT CREDIT OR 3
REFUND OF OVERPAYMENTS OR INCREASE 4
ESTIMATED TAXES. 5
(a) IN GENERAL.—Section 965(h) of the Internal 6
Revenue Code of 1986 is amended by adding at the end 7
the following new paragraph: 8
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‘‘(7) INSTALLMENTS NOT TO PREVENT CREDIT 1
OR REFUND OF OVERPAYMENTS OR INCREASE ESTI-2
MATED TAXES.—If an election is made under para-3
graph (1) to pay the net tax liability under this sec-4
tion in installments— 5
‘‘(A) no installment of such net tax liabil-6
ity shall— 7
‘‘(i) in the case of a request for credit 8
or refund, be taken into account as a li-9
ability for purposes of determining whether 10
an overpayment exists for purposes of sec-11
tion 6402 before the date on which such 12
installment is due, or 13
‘‘(ii) for purposes of sections 6425, 14
6654, and 6655, be treated as a tax im-15
posed by section 1, section 11, or sub-16
chapter L of chapter 1, and 17
‘‘(B) the first sentence of section 6403 18
shall not apply with respect to any such install-19
ment.’’. 20
(b) LIMITATION ON PAYMENT OF INTEREST.—In the 21
case of the portion of any overpayment which exists by 22
reason of the application of section 965(h)(7) of the Inter-23
nal Revenue Code of 1986 (as added by this section)— 24
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(1) if credit or refund of such portion is made 1
on or before the date which is 45 days after the date 2
of the enactment of this Act, no interest shall be al-3
lowed or paid under section 6611 of such Code with 4
respect to such portion; and 5
(2) if credit or refund of such portion is made 6
after the date which is 45 days after the date of the 7
enactment of this Act, no interest shall be allowed 8
or paid under section 6611 of such Code with re-9
spect to such portion for any period before the date 10
of the enactment of this Act. 11
(c) EFFECTIVE DATE.—The amendment made by 12
subsection (a) shall take effect as if included in section 13
14103 of Public Law 115–97. 14
Æ
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