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International Competition for American Jobs Act

5/10/2023, 3:45 AM

Congressional Summary of S 5349

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.

Current Status of Bill S 5349

Bill S 5349 is currently in the status of Bill Introduced since December 21, 2022. Bill S 5349 was introduced during Congress 117 and was introduced to the Senate on December 21, 2022.  Bill S 5349's most recent activity was Read twice and referred to the Committee on Finance. as of December 21, 2022

Bipartisan Support of Bill S 5349

Total Number of Sponsors
1
Democrat Sponsors
0
Republican Sponsors
1
Unaffiliated Sponsors
0
Total Number of Cosponsors
0
Democrat Cosponsors
0
Republican Cosponsors
0
Unaffiliated Cosponsors
0

Policy Area and Potential Impact of Bill S 5349

Primary Policy Focus

Taxation

Alternate Title(s) of Bill S 5349

International Competition for American Jobs Act
International Competition for American Jobs Act
A bill to amend the Internal Revenue Code of 1986 to modify certain provisions relating to the taxation of international entities.

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