Bill > S780

This bill proposes several key changes to the tax treatment of foreign income for U.S. corporations: 1. It eliminates the exemption for certain returns from tangible investments made overseas, requiring the current year inclusion of "net CFC tested income" rather than "global intangible low-taxed income." 2. It repeals the reduced rate of tax on net CFC tested income, effectively increasing the tax rate on such income. 3. It limits the tax deduction for interest expenses of U.S. corporations that are members of an international financial reporting group, based on the group's reported net interest expense. 4. It modifies the rules for the taxation of "inverted" corporations (U.S. corporations that acquire foreign companies to reincorporate overseas) by expanding the definitions and criteria for when a foreign corporation will be treated as a domestic corporation for tax purposes. 5. It allows the IRS to treat certain foreign corporations as domestic corporations for income tax purposes if their management and control primarily occurs in the United States, regardless of their formal place of incorporation. The overall effect of the bill is to reduce or eliminate various tax advantages and deductions related to the foreign operations and income of U.S. corporations, in an effort to discourage the practice of "outsourcing" and incentivize keeping business activities and investments within the United States.

Budget and Finance

https://www.congress.gov/bill/116th-congress/senate-bill/780/all-info