The "International Competition for American Jobs Act" proposes substantial reforms to the taxation of international entities under the Internal Revenue Code, primarily aimed at enhancing the competitiveness of U.S. businesses. A core provision makes permanent the "look-thru rule" for controlled foreign corporations, preventing certain related-party payments between CFCs from being treated as Subpart F income. The bill significantly modifies the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) , maintaining higher deduction rates of 37.5% for FDII and 50% for GILTI beyond 2025. It also revises the Base Erosion Minimum Tax (BEAT) by allowing general business credits against it and expanding exceptions for certain payments, such as those subject to sufficient foreign tax or U.S. tax. These changes aim to reduce the BEAT's impact on U.S. companies. Further reforms impact the foreign tax credit system, including the elimination of the separate foreign branch income and GILTI limitation baskets, consolidating them into the general limitation basket. Crucially, the bill repeals the 80% foreign tax credit haircut for GILTI , allowing U.S. companies to claim 100% of foreign taxes paid on GILTI. It also clarifies that a foreign tax is creditable if its predominant character is an income tax, regardless of nexus. The legislation narrows the scope of Subpart F income by eliminating foreign base company sales income and foreign base company services income from its definition, and exempts corporations from Subpart F inclusion for investments in U.S. property. It also restores limitations on downward attribution of stock ownership for controlled foreign corporation determinations, while introducing new rules for "foreign controlled United States shareholders." Additionally, the bill allows for the carryover of net CFC tested losses to offset future GILTI inclusions and provides special rules to facilitate the repatriation of intangible property from controlled foreign corporations to U.S. shareholders without immediate tax recognition.