Corporate Tax Dodging Prevention Act

Summary

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).

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3 official files

• Introduced in Senate (text)

  Introduced in Senate · EN · 9 March 2017

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• Introduced in Senate (PDF)

  Introduced in Senate · EN · 9 March 2017

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• Introduced in Senate

  summary · EN · 9 March 2017

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