Corporate Tax Dodging Prevention Act: New Rules for Businesses
This act modifies the Internal Revenue Code regarding corporate taxation, specifically targeting international business operations to prevent tax avoidance. It restores progressive corporate tax rates and changes rules regarding foreign income, tax credits, and interest deductions. The bill also addresses inverted corporations and foreign corporations managed within the United States.
Key points
Restoration of progressive corporate tax rates ranging from 15% to 35%.
Equalization of tax rates on domestic and foreign income by modifying Subpart F income definitions.
Introduction of country-by-country application for foreign tax credit limitations.
Limitation on interest deduction for domestic corporations that are part of international financial reporting groups.
Modification of rules for inverted corporations, treating them as domestic if ownership change exceeds 50%.
Treatment of foreign corporations managed and controlled in the U.S. as domestic for tax purposes.
Modifications to the Base Erosion and Anti-Abuse Tax (BEAT), increasing the rate to 12.5% and lowering the threshold to $25 million.
Limitations on foreign tax credits for oil, gas, mining, and gambling taxpayers receiving specific economic benefits.
Limitations on treaty benefits for certain deductible related-party payments.
Repeal of the deduction for foreign-derived intangible income (FDII).
Expired
Additional Information
Print number: 117_S_991
Sponsor: Sen. Sanders, Bernard [I-VT]
Process start date: 2021-03-25