International Tax Changes: Supporting American Jobs and Business Competitiveness
This act modifies tax rules for international businesses to enhance the competitiveness of American companies and safeguard U.S. jobs. The changes aim to simplify certain provisions and adjust how foreign income is taxed for large corporations, potentially impacting their financial obligations.
Key points
Permanently extends the "look-thru" rule for controlled foreign corporations, simplifying tax calculations for some businesses.
Modifies deductions for foreign-derived intangible income and global intangible low-taxed income, potentially altering corporate tax burdens.
Revises rules for the base erosion minimum tax, introducing new exceptions for certain payments.
Establishes new rules for allocating deductions to foreign source global intangible low-taxed income, affecting foreign tax credit calculations.
Restores limitations on downward attribution of stock ownership, which may impact the definition of controlled foreign corporations.
Expired
Additional Information
Print number: 117_S_5349
Sponsor: Sen. Portman, Rob [R-OH]
Process start date: 2022-12-21