Referred to the House Committee on Ways and Means.
This bill rewrites several international tax rules to reduce incentives for shifting profits and operations offshore. It replaces the GILTI regime language with a current-year “net CFC tested income” inclusion, applies foreign tax credit limitations on a country-by-country basis, and tightens rules on interest deductions, inversions, and U.S.-managed foreign corporations.
Liberals focus on tax fairness and closing loopholes; conservatives stress competitiveness and burdens.
Relative to its intended legislative type, this bill is a substantive tax-policy statute that is highly specific in statutory mechanics and well integrated with existing Internal Revenue Code provisions.
This bill rewrites several international tax rules to reduce incentives for shifting profits and operations offshore.
It replaces the GILTI regime language with a current-year “net CFC tested income” inclusion, applies foreign tax credit limitations on a country-by-country basis, and tightens rules on interest deductions, inversions, and U.S.-managed foreign corporations.
It also repeals the reduced-rate deduction for FDII, increases the deemed-paid foreign tax credit, eliminates FTC carrybacks, and treats certain oil-related foreign income as Subpart F income.
Substantive, complex corporate tax rewrite that narrows planning opportunities; likely revenue-positive but faces heavy industry pushback and requires cross‑chamber compromise.
Relative to its intended legislative type, this bill is a substantive tax-policy statute that is highly specific in statutory mechanics and well integrated with existing Internal Revenue Code provisions. It provides clear amendments, definitions, and effective dates and grants regulatory authority where administrative detail is required.
Liberals focus on tax fairness and closing loopholes; conservatives stress competitiveness and burdens.
These are examples from the analysis, not a ranked list of the most-affected groups.
Liberals focus on tax fairness and closing loopholes; conservatives stress competitiveness and burdens.
Likely broadly supportive: the bill curbs corporate profit-shifting, closes tax loopholes, and aims to ensure multinationals pay U.S. tax on U.S.-connected activity.
It aligns with goals to protect the domestic tax base and discourage inversions and offshore tax sheltering.
Cautiously supportive of the bill’s objective to curb base erosion, but concerned about complexity, retroactivity, and international competitiveness.
Wants clear, phased implementation and regulatory detail to avoid unintended economic disruption.
Likely opposed: views the bill as punitive to multinational businesses, increasing taxes and regulatory burdens that harm competitiveness.
Sees retroactivity and broad definitions as risks to investment and market certainty.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Substantive, complex corporate tax rewrite that narrows planning opportunities; likely revenue-positive but faces heavy industry pushback and requires cross‑chamber compromise.
The bill has not accumulated any surfaced votes yet.
Liberals focus on tax fairness and closing loopholes; conservatives stress competitiveness and burdens.
Substantive, complex corporate tax rewrite that narrows planning opportunities; likely revenue-positive but faces heavy industry pushback a…
Relative to its intended legislative type, this bill is a substantive tax-policy statute that is highly specific in statutory mechanics and well integrated with existing Internal Revenue Code provisions. It provides cle…
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