To amend the Internal Revenue Code of 1986 to provide that certain payments to foreign related parties subject to sufficient foreign tax are not treated as base erosion payments.

Bill 119 HR 1911, also known as the "Foreign Tax Credit Protection Act," aims to amend the Internal Revenue Code of 1986 in order to clarify that certain payments made to foreign related parties, which are subject to sufficient foreign tax, should not be considered as base erosion payments.

The bill seeks to address concerns regarding the treatment of payments made to foreign related parties for tax purposes. Specifically, it aims to ensure that payments made to foreign related parties that are subject to an adequate amount of foreign tax are not unfairly penalized or categorized as base erosion payments.

By making this amendment to the Internal Revenue Code, the bill aims to provide clarity and certainty for taxpayers engaging in transactions with foreign related parties. This clarification is intended to prevent unintended consequences and ensure that taxpayers are not unfairly penalized for engaging in legitimate business transactions. Overall, the Foreign Tax Credit Protection Act seeks to promote fairness and transparency in the tax treatment of payments made to foreign related parties, while also providing certainty for taxpayers and reducing the risk of base erosion.