S-5349 : Still Just a Bill

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.