International Competition for American Jobs Act

Summary

International Competition for American Jobs Act This bill modifies provisions relating to the taxation of foreign entities. Among other provisions, the bill makes permanent the look-thru rule for controlled foreign corporations (CFCs). (A look-thru rule provides that dividends, interest, rents and royalties that one CFC receives or accrues from a related CFC are not treated as foreign personal holding company income); modifies the tax deduction for foreign-derived intangible income and global intangible low-taxed income; modifies the base erosion minimum tax (10% minimum tax imposed to prevent corporations operating in the United States from avoiding tax liability by shifting profits out of the United States); modifies tax rules allocating certain tax deductions for purposes of the foreign tax credit limitation; restores the limitation on the attribution of stock ownership for purposes of applying constructive ownership rules; and includes specified amounts in the gross income of CFC shareholders.

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Documents

3 official files

• Introduced in Senate (text)

  Introduced in Senate · EN · 21 December 2022

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• Introduced in Senate (PDF)

  Introduced in Senate · EN · 21 December 2022

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• Introduced in Senate

  summary · EN · 21 December 2022

  Open at official source

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