Corporate Tax Dodging Prevention Act

Corporate Tax Dodging Prevention Act

This bill amends the Internal Revenue Code, with respect to the taxation of the foreign-source income of domestic corporations, to:

• eliminate the deferral of tax on the foreign-source income of U.S. corporations for taxable years beginning after December 31, 2017;
• include previously deferred foreign-source income of corporations as taxable income;
• deny the foreign tax credit to large integrated oil companies that are dual capacity taxpayers;
• limit the offset of the foreign tax credit to income that is subject to U.S. tax;
• treat foreign corporations managed and controlled in the United States as domestic corporations for U.S. tax purposes;
• limit the tax deduction of the interest expense of a U.S. corporation that is a member of a financial reporting group (i.e., a group that prepares consolidated financial statements according to generally accepted accounting principles or international financial reporting standards); and
• revise rules for the taxation of inverted corporations (i.e., U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States) to provide 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, after such acquisition it holds more than 50% of the stock of the new entity (expanded affiliated group).