On the recordDecember 3, 2014
I reserve a point of order against the motion to recommit. The SPEAKER pro tempore. A point of order is reserved. The Clerk will report the motion to recommit. The Clerk read as follows: Mr. NEAL moves to recommit the bill H.R. 5771 to the Committee on Ways and Means with instructions to report the same back to the House forthwith with the following amendment: Add at the end of title I the following (and conform the table of contents accordingly): Subtitle E--No Government Subsidies for Corporations That Move Their Headquarters Overseas to Avoid Paying Taxes SEC. 191. TAX BENEFITS DISALLOWED IN CASE OF INVERTED CORPORATIONS. (a) In General.--In the case of a taxpayer which is, or is a member of an expanded affiliated group which includes, an applicable inverted corporation, the Internal Revenue Code of 1986 shall be applied and administered as if the provisions of, and amendments made by, this title (other than this subtitle) had never been enacted. (b) Applicable Inverted Corporations.-- (1) In general.--For purposes of this section, the term ``applicable inverted corporation'' means any foreign corporation which-- (A) would be a surrogate foreign corporation under subsection (a)(2) of section 7874 of the Internal Revenue Code of 1986 if such subsection were applied by substituting ``80 percent'' for ``60 percent'', or (B) is an inverted domestic corporation.…
