Bill > S1636

This bill amends the Internal Revenue Code to revise the rules for the taxation of inverted corporations. An "inverted corporation" refers to a U.S. corporation that acquires a foreign company to reincorporate in a foreign jurisdiction with lower income tax rates than the United States. The bill provides that a foreign corporation that acquires the properties of a U.S. corporation or partnership after May 8, 2014, shall be treated as an inverted corporation and thus subject to U.S. taxation if more than 50% of the stock of the new entity is held by former shareholders or partners of the U.S. entity, or if the management and control of the new entity primarily occurs within the U.S. and the new entity has significant domestic business activities. The bill also includes provisions for determining when a foreign corporation has "substantial business activities" in the foreign country where it is organized, to be exempted from the inverted corporation treatment.

Budget and Finance

https://www.congress.gov/bill/115th-congress/senate-bill/1636/all-info