Bill > HR1911

This bill amends the Internal Revenue Code to modify how certain payments to foreign related parties are treated for tax purposes. Specifically, the bill creates a new provision that allows taxpayers to exempt payments from being classified as "base erosion payments" (a type of payment that could potentially reduce U.S. tax liability) if two key conditions are met: (1) the foreign recipient of the payment is subject to a foreign income tax rate of at least 15%, and (2) the payment itself is subject to a foreign income tax rate of at least 15%. The bill provides detailed guidance on how to calculate this effective tax rate, allowing taxpayers to use financial statements with adjustments for various accounting factors like dividends, currency gains/losses, and other specified items. The Secretary of the Treasury is granted authority to create regulations to implement this provision, including procedures for determining the tax rate and preventing potential tax avoidance strategies. The amendments will apply to taxable years beginning after the date of the Act's enactment, providing a clear timeline for implementation of these new tax treatment rules.

Budget and Finance

https://www.congress.gov/bill/119th-congress/house-bill/1911/all-info