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.