HF2669 Summary

• Expands definition of "domestic corporation" to include corporations incorporated in tax havens, engaged in substantial tax haven business, or with 20% or more of property/payroll/sales factors in the U.S., effective for returns filed after December 31, 2011.

• Establishes list of 34 designated tax haven jurisdictions (including Cayman Islands, Panama, Bahamas, and others) that lose tax haven status upon U.S. entry into tax treaty with automatic information exchange.

• Repeals "foreign operating corporation" provisions and related income add-backs for deemed dividends, interest/intangible expenses paid to foreign entities, and foreign entity income, effective for taxable years beginning after December 31, 2011.

• Increases top individual income tax rate to 10.85% on income over $1,000,000 and adjusts income tax brackets upward; changes inflation adjustment base year from 2000 to 2012.

• Removes exemption allowing foreign operating corporations to file separate returns and excludes their income from unitary business reporting requirements.