This bill modifies U.S. tax laws to benefit American corporations with foreign operations and domestic research activities. It increases the deduction for foreign-derived intangible income from 33.34% to 40%, broadens what income qualifies for this deduction, and simplifies the foreign tax credit system by consolidating tax categories and allowing corporations to allocate certain deductions against foreign-source income—all effective for tax years beginning after December 31, 2026. The bill also exempts certain controlled foreign corporations from taxation on investments in U.S. property and directs the Treasury Department to prevent research and development expenses from being double-counted across affiliated corporations. These changes are intended to increase the competitiveness of U.S. businesses in global markets while addressing tax compliance issues within corporate groups.