Amends the Internal Revenue Code to modify provisions affecting the taxation of international entities, including changes to foreign tax credits.

The bill amends the Internal Revenue Code to modify various provisions affecting the taxation of international entities. Key changes include adjustments to the foreign tax credit limitation baskets, modifications to the base erosion minimum tax, and an increase in the deduction for foreign-derived intangible income from 33.34% to 40%. It also introduces special rules for transfers of intangible property from controlled foreign corporations to U.S. shareholders, and eliminates the inclusion of foreign base company sales income and foreign base company services income.

Amends the Internal Revenue Code to modify provisions affecting the taxation of international entities, including changes to foreign tax credits.

The bill amends the Internal Revenue Code to modify various provisions affecting the taxation of international entities. Key changes include adjustments to the foreign tax credit limitation baskets, modifications to the base erosion minimum tax, and an increase in the deduction for foreign-derived intangible income from 33.34% to 40%. It also introduces special rules for transfers of intangible property from controlled foreign corporations to U.S. shareholders, and eliminates the inclusion of foreign base company sales income and foreign base company services income.