Bill > HR2423

This bill modifies the Base Erosion and Anti-Abuse Tax (BEAT), a provision of the U.S. tax code targeting multinational corporations that shift profits to foreign subsidiaries to reduce U.S. tax liability. Specifically, the bill creates special tax rules for "foreign-owned extraterritorial tax regime entities," which are taxpayers controlled by foreign entities in countries that impose taxes based on a company's global income or connections. Under these new rules, such entities will be more strictly evaluated for BEAT purposes: they will be automatically considered applicable taxpayers, have their base erosion payment calculation date reset, have certain existing tax exemptions removed, and have 50% of their cost of goods sold treated as a base erosion tax benefit. The bill defines an "extraterritorial tax" as any foreign tax determined by a corporation's global income or ownership connections, regardless of direct ownership interests. These new provisions would apply to taxable years beginning after the bill's enactment and are aimed at preventing tax avoidance strategies by multinational corporations operating across different tax jurisdictions.

Budget and Finance

https://www.congress.gov/bill/119th-congress/house-bill/2423/all-info