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S. 2786

BillFederalSenateIn Committee
Corporate Inverters Earnings Stripping Reform Act of 2014
About This Bill
Committee
Latest Action · September 10, 2014
Read twice and referred to the Committee on Finance.
Congress
113th (2013–2015)
Introduced
September 10, 2014
Sponsor
Sen. Charles SchumerD
Cosponsors (14)
14D 0R
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Summary

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Corporate Inverters Earnings Stripping Reform Act of 2014 - Amends the Internal Revenue Code to impose limitations on the tax deduction for interest paid by corporations which are designated as applicable entities (i.e., members of an expanded affiliated group which includes a surrogate foreign corporation which is not treated as a domestic corporation). Prohibits such an entity from claiming a tax deduction for interest that exceeds 25% of its adjusted taxable income and from carrying forward interest which is paid or accrued during the first year in which such entity becomes an applicable entity. Requires an applicable entity to file an annual application for an approval agreement (i.e., a prefiling, advance pricing, or other agreement involving a related-party transaction) with the Internal Revenue Service (IRS) during the 10-year period after it becomes an applicable entity.

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