Foreign Investment Incentive Act: Hearings Before the Committee on Ways and Means, House of Representatives, Eighty-sixth Congress, First Session, on H.R. 5, a Bill to Amend the Internal Revenue Code of 1954 to Encourage Private Investment Abroad and Thereby Promote American Industry and Reduce Government Expenditures for Foreign Economic Assistance, July 7, 8, and 9, 1959

Front Cover
Considers H.R. 5, the Foreign Investment Incentive Tax Act of 1959, to provide tax incentives to encourage capital investment and trade expansion with developing countries, especially by small businesses.
 

Contents

Atlas Asbestos Co W H Johnston general manager letter dated June
30
Goodyear Tire Rubber Co statement
38
Stam Colin F chief of staff Joint Committee on Internal Revenue Tax
45
State Under Secretary of Hon Douglas Dillon_
77
Dillion Hon Douglas Under Secretary of State letter dated July 28 1959
96
109
96
Burgess Ralph E economist American Cyanamid Co
97
The only instrument for economic development the United States
100
Moore G C export manager the Heald Machine Co letter dated July
109
There is no possible way for shareholders of U S corporations
110
Aluminum Co of America Leon E Hickman executive vice president
116
Steele H y Cia S A Mexico City Norman W Gottlieb 465
142
First National City Bank of New York William A Patty counsel 404
150
Quinn Paul J vice president Johnson Johnson International draft
155
Dixson Robert J president Johnson Johnson letter dated July 17 1959
156
Gottlieb Norman W H Steele y Cia S A Mexico City 465
163
Straus Ralph I 240
168
Red Star Yeast Products Co Stanley Applegate director of foreign
171
American Chambers of Commerce for Brazil Richard P Momsen_
181
Export Trade Redington Fiske editor statement 496
188
Gushman John L vice president OwensIllinois Glass Co 308
192
Vick Chemical Co Sherwood E Silliman secretary 446
197
American Cyanamid Co Ralph E Burgess economist
207
exports
213
Joint Committee on Revenue Taxation Colin F Stam chief of staff letter
217
Letter from Peat Marwick Mitchell Co to Congressman Boggs
220
Kaiser Industries Corp Chad F Calhoun vice president statement 472
239
Straus Ralph I report entitled Expanding Private Investment for Free
247
Nationwide Committee on ImportExport Policy O R Strackbein
275
Haynes Eldridge president Business International_ 96
299
Calhoun Chad F vice president Kaiser Industries Corp statement 472
312
Christopherson Carl E manager international trade department World
405
hearings on the bill H R 5 the Foreign Investment Incentive Tax Act
422
New York Board of Trade Inc Paul D Seghers chairman international
431
Federal Tax Forum Inc Paul D Seghers chairman Committee on Fed
437
H R 5 86th Cong 1st sess
438
Crichley William A chairman tax policy committee Manufacturing
443
Celanese Corp of America Lawrence S Apsey general attorney letter
463
Dillon Hon Douglas Under Secretary of State 77
467
Nutter Charles managing director International House 323
469
Heald Machine Co G C Moore export manager letter dated July
476
Sunbeam Corp Herman T Van Mell vice president and general counsel
478
Pfizer International Inc John J Powers Jr president and chairman
481
Chrysler Corp statement_
490
A BILL To amend the Internal Revenue Code of 1954 to encourage private investment
494
KimberlyClark Corp statement
497
Automobile Manufacturers Association statement
515
Texas Independent Producers Royalty Owners Association Harry C
522
Shaw Barclay secretary National Association of Insurance Brokers Inc
532
III
Babcock N N treasurer Talon Inc letter dated July 20 1959
558
Finch H A manager of marketing Jones Lamson Machine Co letter
611
Boggs Richard H and Richard Holzer international executive members
Skil Corp Charles R Beauregard comptroller and William A Mihelich
Powers John J Jr president and chairman of the board Pfizer Inter
American Foreign Insurance Association James O Nichols president
Klein P C president Mercator Corp letter dated July 13 1959
American Institute of Certified Public Accountants Wallace M Jensen
McCormick J E vice president and treasurer Dole Hawaiian Pineapple
Textile Machine Works L P Garrigan manager letter dated July

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Page 3 - Except as otherwise expressly provided, whenever in this Act an amendment or repeal is expressed in terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1954.
Page 6 - In section 332, 361, 364, 355, 356, or 361, a foreign corporation shall not be considered as a corporation unless, before such exchange. It has been established to the satisfaction of the Secretary or his delegate that such exchange Is not In pursuance of a plan having as one of its principal purposes the avoidance of Federal Income taxes. For purposes of this section, any distribution described In section 355 (or so much of section 356 as relates to section 355) shall be treated as an exchange whether...
Page 58 - A statement setting forth the various classes of stock outstanding, the name and address of each shareholder, the class and number of shares held by each on the date of payment of the dividend with respect to which the claim...
Page 137 - Be it enacted by the Senate and Bouse of Representatives of the United States of America in Congress assembled, That this Act may be cited as the "Housing Amendments of 1957".
Page 391 - In the case of a domestic corporation engaged in business in a foreign country, its assets and liabilities (other than capital assets) recorded on its books in terms of the foreign currency, should be appraised in dollars (whether actually converted or not) at the close of each taxable year in which it is engaged in active business at the current or market rate of exchange, if any, then prevailing. (But see ARB 15, 3-20-682.)" (Italics supplied.) Under this version of the balance sheet method, all...
Page 14 - In the case of a foreign corporation the deductions shall be allowed only if and to the extent that they are connected with income from sources within the United States ; and the proper apportionment and allocation of the deductions with respect to sources within and without the United States shall be determined as provided in section 119, under rules and regulations prescribed by the Commissioner with the approval of the Secretary. (b) CHARITABLE, AND so FORTH, CONTRIBUTIONS. — The so-called "charitable...
Page 5 - ... of such plan year shall be deemed to have been made on the last day of such year.
Page 16 - For purposes of this subpart and of sections 164(a) and 275 (a), the term "income, war profits, and excess profits taxes shall include a tax paid in lieu of a tax on income, war profits, or excess profits otherwise generally imposed by any foreign country or by any possession of the United States.
Page 15 - Code, and the regulations thereunder, or under the provisions of an applicable tax convention, shall not be included in the gross income of a nonresident alien individual.
Page 300 - The challenge to America is to exert the necessary leadership for successfully directing its capabilities to the maintenance of freedom and peace. The United States must demonstrate to the world that a dynamic, expanding, competitive capitalism is a major factor contributing to the more abundant life that people everywhere are seeking. For an economy to be dynamic and expanding, goods and capital must flow freely. This requires world trade and world investment, with governments encouraging private...

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