Read twice and referred to the Committee on Finance.
This bill changes many international tax rules in the Internal Revenue Code to alter how U.S. multinationals are taxed. Major changes include modifying FDII/GILTI deductions, revising BEAT and foreign tax credit rules, changing Subpart F and constructive ownership rules, and adding special rules for intangibles and Virgin Islands service income.
Liberals emphasize revenue loss and increased avoidance risk.
Relative to its intended legislative type, this bill is a detailed substantive tax code revision: it contains extensive, specific statutory amendments affecting international taxation, with clear textual mechanics and effective dates, but it omits an explicit problem statement, fiscal/resource acknowledgements, and formal oversight or reporting requirements.
This bill changes many international tax rules in the Internal Revenue Code to alter how U.S. multinationals are taxed.
Major changes include modifying FDII/GILTI deductions, revising BEAT and foreign tax credit rules, changing Subpart F and constructive ownership rules, and adding special rules for intangibles and Virgin Islands service income.
Most provisions take effect for taxable years beginning after December 31, 2025.
Substantial, revenue‑affecting overhaul of international tax rules; complexity and fiscal cost make enactment unlikely without major negotiations and offsets.
Relative to its intended legislative type, this bill is a detailed substantive tax code revision: it contains extensive, specific statutory amendments affecting international taxation, with clear textual mechanics and effective dates, but it omits an explicit problem statement, fiscal/resource acknowledgements, and formal oversight or reporting requirements.
Liberals emphasize revenue loss and increased avoidance risk.
These are examples from the analysis, not a ranked list of the most-affected groups.
Liberals emphasize revenue loss and increased avoidance risk.
Views the bill as a package of corporate tax relief measures that loosen anti-avoidance rules.
Sees risks to federal revenue and potential profit-shifting incentives.
Would demand stronger anti-abuse provisions and revenue offsets.
Sees the bill as a technical, pro-competitiveness rewrite with tradeoffs between business relief and revenue.
Wants independent scoring, clarity from Treasury regulations, and guardrails against erosion of the tax base.
Will weigh whether benefits to U.S. jobs and investment justify revenue cost.
Views the bill positively as pro-growth reform that reduces tax frictions for U.S. multinationals.
Appreciates broader deductions, reduced double taxation, and relief from certain Subpart F inclusions.
Sees it as strengthening U.S. competitiveness and encouraging onshore investment.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Substantial, revenue‑affecting overhaul of international tax rules; complexity and fiscal cost make enactment unlikely without major negotiations and offsets.
The bill has not accumulated any surfaced votes yet.
Liberals emphasize revenue loss and increased avoidance risk.
Substantial, revenue‑affecting overhaul of international tax rules; complexity and fiscal cost make enactment unlikely without major negoti…
Relative to its intended legislative type, this bill is a detailed substantive tax code revision: it contains extensive, specific statutory amendments affecting international taxation, with clear textual mechanics and e…
Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.