Partnership to Build America Act of 2017

This bill establishes the American Infrastructure Fund (AIF) as a wholly-owned government corporation to provide bond guarantees and make loans to state and local governments, non-profit infrastructure providers, private parties, and public-private partnerships for state or local government sponsored transportation, energy, water, communications, or educational facility infrastructure projects (Qualified Infrastructure Projects [QIPs]). The AIF may also to make equity investments in QIPs.

The Department of the Treasury, acting through the AIF, shall issue American Infrastructure Bonds with an aggregate face value of $50 billion. The proceeds from the sale of the bonds shall be deposited into the AIF.

The bill amends the Internal Revenue Code to allow U.S. corporations to exclude from gross income qualified cash dividend amounts received during a taxable year from a foreign-controlled corporation equal to the face value of qualified infrastructure bonds the corporation has purchased.

The bill prohibits allowance of:

• a foreign tax credit for the excluded portion of any dividend received by a U.S. corporation, and
• a deduction for expenses directly allocable to that excludable portion.