Bill > S1533

This bill, titled the "Stop Tax Haven Abuse Act," aims to curb offshore tax evasion and avoidance by implementing several key provisions. It strengthens the Foreign Account Tax Compliance Act (FATCA), which requires foreign financial institutions to report on accounts held by U.S. taxpayers, by introducing new reporting requirements and presumptions for entities and transactions involving non-FATCA institutions, making it harder to hide assets offshore. The bill also treats foreign corporations managed and controlled in the U.S. as domestic corporations for tax purposes, and requires reporting of U.S. beneficial owners of foreign-owned financial accounts. Furthermore, it introduces measures to prevent corporate offshore tax avoidance by changing how expenses and foreign taxes are allocated, treating excess income from transfers of intangible property to low-taxed affiliates as taxable income, and limiting income shifting through intangible property transfers. The bill also repeals certain "check-the-box" rules for foreign entities and modifies "look-thru" rules for controlled foreign corporations (CFCs), and prohibits offshore loan abuse by U.S. shareholders from CFCs. Additionally, it enhances anti-money laundering requirements for investment advisers and formation agents, strengthens "John Doe" summons proceedings to aid tax investigations, and mandates country-by-country reporting for public companies to disclose their financial performance and tax payments in different jurisdictions.