Per-Country Minimum Act This bill modifies the tax treatment of foreign source income of domestic corporations to: (1) increase taxes that apply to global intangible income by reducing the deduction that is allowed under current law, (2) eliminate a provision that allows companies to deduct a portion of the tangible assets of their controlled foreign corporations (CFCs) before the tax on foreign income applies, and (3) require net CFC tested income to be determined on a country-by-country basis rather than globally.
Foreign and international corporationsIncome tax deductionsTax administration and collection, taxpayersTaxation of foreign income
To amend the Internal Revenue Code of 1986 to increase the tax on certain global intangible income.
USA115th CongressHR-6015| House
| Updated: 6/6/2018
Per-Country Minimum Act This bill modifies the tax treatment of foreign source income of domestic corporations to: (1) increase taxes that apply to global intangible income by reducing the deduction that is allowed under current law, (2) eliminate a provision that allows companies to deduct a portion of the tangible assets of their controlled foreign corporations (CFCs) before the tax on foreign income applies, and (3) require net CFC tested income to be determined on a country-by-country basis rather than globally.