Taxing capital gains on Russian sovereign assets

(a) In general Not later than 15 days after making an affirmative determination under section 301, notwithstanding any other provision of law, there is hereby imposed for each taxable year on the disqualified income of any specified foreign government a tax equal to 100 percent thereof. (b) Withholding (1) In general Notwithstanding section 203 of the International Emergency Economic Powers Act (or any other provision of law), any person having control, receipt, custody, disposal, or payment of disqualified income with respect to which tax is imposed under subsection (a) shall deduct and withhold from such income a tax equal to 100 percent thereof. (2) Application of certain rules For purposes of subchapter B of chapter 3, section 33, and such other provisions as the Secretary may provide, paragraph (1) shall be treated as part of subchapter A of chapter 3. (c) Definitions For purposes of this section: (1) Disqualified income The term disqualified income means any interest or dividends payable with respect to assets which are blocked using the authorities provided by section 203 of the International Emergency Economic Powers Act. (2) Specified foreign government The term specified foreign government means the foreign governments (within the meaning of section 892 of the Internal Revenue Code of 1986 and the regulations issued thereunder) of Russia and Belarus. (d) Override of treaty obligations Notwithstanding any other provision of law, this section (and the amendments made by this section) shall apply without regard to any treaty obligation of the United States. (e) Effective date The amendments made by this section shall apply to interest and dividends received after the date of the enactment of this Act.

(a) In general Not later than 15 days after making an affirmative determination under section 301, notwithstanding any other provision of law, there is hereby imposed for each taxable year on the disqualified income of any specified foreign government a tax equal to 100 percent thereof. (b) Withholding (1) In general Notwithstanding section 203 of the International Emergency Economic Powers Act (or any other provision of law), any person having control, receipt, custody, disposal, or payment of disqualified income with respect to which tax is imposed under subsection (a) shall deduct and withhold from such income a tax equal to 100 percent thereof. (2) Application of certain rules For purposes of subchapter B of chapter 3, section 33, and such other provisions as the Secretary may provide, paragraph (1) shall be treated as part of subchapter A of chapter 3. (c) Definitions For purposes of this section: (1) Disqualified income The term disqualified income means any interest or dividends payable with respect to assets which are blocked using the authorities provided by section 203 of the International Emergency Economic Powers Act. (2) Specified foreign government The term specified foreign government means the foreign governments (within the meaning of section 892 of the Internal Revenue Code of 1986 and the regulations issued thereunder) of Russia and Belarus. (d) Override of treaty obligations Notwithstanding any other provision of law, this section (and the amendments made by this section) shall apply without regard to any treaty obligation of the United States. (e) Effective date The amendments made by this section shall apply to interest and dividends received after the date of the enactment of this Act.