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S. 327 · Senate bill · 119th Congress
This bill prohibits a taxpayer from claiming the foreign tax credit (FTC) or an itemized tax deduction for taxes paid, accrued, or deemed paid to Russia.
Under current law, a taxpayer may claim the FTC for income, war profits, and excess profits taxes (or taxes imposed in lieu of these taxes) paid, accrued, or deemed paid to a foreign country (and certain U.S. possessions) or an itemized tax deduction for such taxes, both subject to limitations.
However, under current law, a taxpayer may not claim the FTC (but may claim an itemized tax deduction) for taxes paid to a foreign country if (1) the United States does not recognize the country’s government, (2) the United States severs or does not conduct diplomatic relations with the country, or (3) the country is designated by the Department of State as supporting international terrorist acts. (Currently, the FTC is disallowed for taxes paid, accrued, or deemed paid to Iran, North Korea, Sudan, and Syria.)
Under the bill, a taxpayer may not claim the FTC for taxes paid, accrued, or deemed paid to Russia beginning 30 days after the date of enactment and until normal U.S. trade relations with Russia are restored (pursuant to requirements established by the Suspending Normal Trade Relations with Russia and Belarus Act).
The bill also disallows an itemized tax deduction for taxes paid, accrued, or deemed to be paid to Russia (effective 90 days after the date of enactment).
This Act may be cited as the “Hindering Oppressive Nations from Obtaining Revenue Act” or “HONOR Act”.
(a) In general.— Section 901(j)(2) of the Internal Revenue Code of 1986 is amended by adding at the end the following new subparagraph:
“(C) Special rule for Russia.—
(i) In general.— This subsection shall apply to the Russian Federation during the period described in clause (ii).
(ii) Period of application.— The period described in this clause with respect to any country is the period—
(I) beginning on the date that is 30 days after the date of the enactment of this subparagraph, and
(II) ending on the date on which the resumption of the application of the rates of duty set forth in column 1 of the Harmonized Tariff Schedule of the United States to products of that country takes effect pursuant to section 4(b) of the Suspending Normal Trade Relations with Russia and Belarus Act.”.
(b) Deduction denied.— Section 901(j)(3) of such Code is amended by adding at the end the following new sentence: “The preceding sentence shall not apply to any tax of any country to which paragraph (2)(C) applies.”.
(c) Effective dates.—
(1) In general.— Except as provided in paragraph (2), the amendments made by this section shall take effect on the date of the enactment of this Act.
(2) Deduction limitation.— The amendment made by subsection (b) shall apply to taxes paid or accrued (or deemed paid or accrued under section 960 of the Internal Revenue Code of 1986) after the date that is 90 days after the date of the enactment of this Act.
(3) Nonapplication of treaty rules.— This section and the amendments made by this section shall be applied without regard to any treaty obligation of the United States.