PlainBillCongress, translated.Legislation. Context. Public interest.Read twice and referred to the Committee on Finance.
Congressional Research Service
Version 00 · Introduced in Senate · Dec 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.
People & committees
Sen. Portman, Rob [R-OH] · R–OH
Legislative record
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Read twice and referred to the Committee on Finance.
Introduced in Senate
Primary sources
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Source last updated: Jan 3, 2025. Consult Congress.gov for the current record.
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