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International Competition for American Jobs Act

USA117th CongressS-5349| Senate 
| Updated: 12/21/2022
Rob Portman

Rob Portman

Republican Senator

Ohio

Finance Committee

  • Introduced
  • In Committee
  • On Floor
  • Passed Chamber
  • Enacted
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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Timeline
Dec 21, 2022
Introduced in Senate
Dec 21, 2022
Read twice and referred to the Committee on Finance.
  • December 21, 2022
    Introduced in Senate


  • December 21, 2022
    Read twice and referred to the Committee on Finance.

Taxation

Related Bills

  • HR 117-5376: Inflation Reduction Act of 2022
  • HR 117-2847: To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations, and for other purposes.

International Competition for American Jobs Act

USA117th CongressS-5349| Senate 
| Updated: 12/21/2022
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.
View Full Text

Suggested Questions

Get AI-generated questions to help you understand this bill better

Timeline
Dec 21, 2022
Introduced in Senate
Dec 21, 2022
Read twice and referred to the Committee on Finance.
  • December 21, 2022
    Introduced in Senate


  • December 21, 2022
    Read twice and referred to the Committee on Finance.
Rob Portman

Rob Portman

Republican Senator

Ohio

Finance Committee

Taxation

Related Bills

  • HR 117-5376: Inflation Reduction Act of 2022
  • HR 117-2847: To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations, and for other purposes.
  • Introduced
  • In Committee
  • On Floor
  • Passed Chamber
  • Enacted