Bill > HR8895

This bill amends the Internal Revenue Code to provide that certain payments made to foreign related parties subject to at least a 15% effective rate of foreign income tax are not treated as "base erosion payments." The bill allows taxpayers to establish the effective foreign tax rate based on their applicable financial statements, with certain adjustments as determined by the Secretary of the Treasury. The bill also authorizes the Secretary to issue regulations for the application of this provision, including procedures for determining the effective foreign tax rate and rules to prevent tax avoidance or abuse. The amendments made by the bill would apply to taxable years beginning after the date of enactment.