This bill amends the Internal Revenue Code of 1986, specifically Section 59A, to modify the definition of base erosion payments . It introduces a new provision stating that certain amounts paid to foreign related parties will not be treated as base erosion payments. This exclusion applies if the taxpayer can demonstrate that both the foreign person receiving the payment and the payment itself are subject to an effective rate of foreign income tax of at least 15 percent . The effective rate of foreign income tax may be established using applicable financial statements, subject to specific adjustments determined by the Secretary of the Treasury. The bill also grants the Secretary authority to issue regulations for implementing this provision, including procedures for calculating the effective tax rate and rules to prevent tax avoidance or abuse. These amendments will apply to taxable years beginning after the date of the bill's enactment.