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S. 5349

BillFederalSenateIn Committee
To amend the Internal Revenue Code of 1986 to modify certain provisions relating to the taxation of international entities.
About This Bill
Committee
Latest Action · December 21, 2022
Read twice and referred to the Committee on Finance.
Congress
117th (2021–2023)
Introduced
December 21, 2022
Cosponsors (0)
None
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Summary

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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.

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