This bill modifies the tax treatment of the foreign source income of domestic corporations. The bill includes provisions that
modify calculations of the gross income of U.S. shareholders to include net controlled foreign corporation (CFC) tested income in the current taxable year;
apply limitations on the foreign tax credit on a country-by-country basis;
limit the tax deduction for the interest expense of a U.S. corporation that is a member of an international financial reporting group (i.e., a group that prepares consolidated financial statements according to generally accepted accounting principles or international financial reporting standards);
modify the 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); and
treat certain foreign corporations managed and controlled primarily in the United States as domestic corporations for tax purposes.
Actions
Feb 9, 2023
Referred to the House Committee on Ways and Means.