International Competition for American Jobs Act

5/10/2023, 3:45 AM

International Competition for American Jobs Act

This bill modifies provisions relating to the taxation of foreign entities.

Among other provisions, the bill

  • makes permanent the look-thru rule for controlled foreign corporations (CFCs). (A look-thru rule provides that dividends, interest, rents and royalties that one CFC receives or accrues from a related CFC are not treated as foreign personal holding company income);
  • modifies the tax deduction for foreign-derived intangible income and global intangible low-taxed income;
  • modifies the base erosion minimum tax (10% minimum tax imposed to prevent corporations operating in the United States from avoiding tax liability by shifting profits out of the United States);
  • modifies tax rules allocating certain tax deductions for purposes of the foreign tax credit limitation;
  • restores the limitation on the attribution of stock ownership for purposes of applying constructive ownership rules; and
  • includes specified amounts in the gross income of CFC shareholders.
Congress
117
Number
S - 5349
Introduced on
2022-12-21
# Amendments
0
Sponsors
+5

Variations and Revisions

12/21/2022
Text
PDF
XML

Status of Legislation

Bill Introduced
Introduced to House
House to Vote
Introduced to Senate
Senate to Vote

Purpose and Summary

International Competition for American Jobs Act

This bill modifies provisions relating to the taxation of foreign entities.

Among other provisions, the bill

  • makes permanent the look-thru rule for controlled foreign corporations (CFCs). (A look-thru rule provides that dividends, interest, rents and royalties that one CFC receives or accrues from a related CFC are not treated as foreign personal holding company income);
  • modifies the tax deduction for foreign-derived intangible income and global intangible low-taxed income;
  • modifies the base erosion minimum tax (10% minimum tax imposed to prevent corporations operating in the United States from avoiding tax liability by shifting profits out of the United States);
  • modifies tax rules allocating certain tax deductions for purposes of the foreign tax credit limitation;
  • restores the limitation on the attribution of stock ownership for purposes of applying constructive ownership rules; and
  • includes specified amounts in the gross income of CFC shareholders.
Alternative Names
Official Title as IntroducedA bill to amend the Internal Revenue Code of 1986 to modify certain provisions relating to the taxation of international entities.
Policy Areas
Taxation

Comments

Related

Member:  Rob Portman
Bill Update Alert:  Inflation Reduction Act of 2022
Bill Update Alert:  To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations, and for other purposes.

Recent Activity

Latest Summary5/9/2023

International Competition for American Jobs Act

This bill modifies provisions relating to the taxation of foreign entities.

Among other provisions, the bill

  • makes permanent the look-thru rule for co...
Latest Action12/21/2022
Read twice and referred to the Committee on Finance.