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Closing Tax Loopholes for International Corporations

This act aims to tighten tax rules for U.S. companies operating abroad. The changes are designed to prevent tax avoidance through artificially repatriating income back to the U.S., potentially increasing government revenue. For most citizens not involved in international business, this act does not directly change daily life.
Key points
The act modifies how taxes on foreign income of companies are calculated to prevent tax avoidance.
It introduces new rules for income that is artificially "round-tripped" back to the U.S. to ensure proper taxation.
Small businesses with annual gross receipts under $100 million are exempt from these new, more complex rules.
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Status: Introduced
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Additional Information
Print number: 119_S_2021
Sponsor: Sen. Wyden, Ron [D-OR]
Process start date: 2025-06-11