Bill > S1605

This bill, the International Competition for American Jobs Act, proposes several significant modifications to the U.S. tax code concerning international business and corporate taxation. Primarily, the bill makes permanent and modifies several existing tax provisions related to foreign-derived income, controlled foreign corporations (CFCs), and international tax credits. Key changes include extending the "look-thru" rule for CFCs, modifying deductions for foreign-derived intangible income and global intangible low-taxed income (GILTI), adjusting the base erosion minimum tax, simplifying foreign tax credit limitation baskets, and introducing new rules for stock ownership attribution. The bill also makes provisions to allow carryover of net CFC tested losses, provides more flexibility in claiming foreign tax credits, and creates special rules for transfers of intangible property from CFCs to U.S. shareholders. Most of these changes are set to take effect for taxable years beginning after December 31, 2025, and aim to provide more clarity and potentially more favorable tax treatment for U.S. corporations with international operations. The bill reflects ongoing efforts to modernize the U.S. international tax system and potentially make U.S. corporations more competitive in the global marketplace.

Budget and Finance

https://www.congress.gov/bill/119th-congress/senate-bill/1605/all-info