S. 5349 · 117th Congress
International Competition for American Jobs Act
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Never voted on. It didn't reach a floor vote before the 117th Congress ended, so it expired. A bill has to be introduced again to be considered in a new Congress.
R
PortmanSponsorNo cosponsors.
This bill modifies provisions relating to the taxation of foreign entities.
What it does: CRS summary · Introduced in Senate · Dec 21, 2022
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.
Written by the nonpartisan Congressional Research Service. All summary versions on Congress.gov
About this bill and sources
Official title: International Competition for American Jobs Act
Latest action (Dec 21, 2022): Read twice and referred to the Committee on Finance.
Policy area: Taxation · Origin: Senate · Introduced: Dec 21, 2022
Official page on Congress.gov · Bill text (GovInfo) · Status record (XML)
No recorded floor vote found.