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This bill creates a tax incentive for U.S. companies to bring intellectual property assets back from foreign subsidiaries to the United States. Under current law, companies face potential tax penalties when moving intangible assets like patents, copyrights, software, and trade secrets from foreign corporations they control to domestic U.S. corporations. The legislation eliminates this tax burden by allowing the foreign property to be transferred at its original cost basis rather than its current market value, and it prevents the U.S. shareholder from recognizing any taxable gain on the transfer. The bill applies to intellectual property held by foreign subsidiaries as of the law's enactment date and to any property transferred through multiple foreign subsidiaries within 180 days, as long as it ultimately reaches a U.S. domestic corporation. The tax incentive would take effect for transfers occurring after December 31, 2023, and is intended to encourage companies to consolidate their intellectual property operations domestically and create jobs in the United States.

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