September 16, 2026

Mr. Estes introduced the following bill; which was referred to the Committee on Ways and Means

A BILL

To amend the Internal Revenue Code of 1986 to modify certain provisions relating to the taxation of international entities.

1. Short title, etc; 2. Modification of deduction for foreign-derived intangible income and net controlled foreign corporation tested income; 3. Modifications to base erosion minimum tax; 4. Modification of foreign tax credit limitation baskets; 5. Carryover of net CFC tested loss; 6. Redetermination of foreign taxes and related claims; 7. Repeal of foreign tax credit haircut for net controlled foreign corporation tested income; 8. Repeal of inclusion percentage applicable to deemed paid credit for taxes properly attributable to tested income; 9. Application of foreign-source dividend deduction to amounts received by controlled foreign corporations; 10. Elimination of inclusion of foreign base company sales income and foreign base company services income; 11. Corporations exempt from subpart F inclusion for investment in United States property; 12. Special rules for transfers of intangible property from controlled foreign corporations to United States shareholders; 13. Net CFC tested income determined without regard to certain income derived from services performed in the United States Virgin Islands; 14. Repeal of modification to definition of adjusted taxable income for purposes of the limitation on business interest; 15. Research credit treated as a specified credit for all taxpayers for purposes of general business credit; 16. Regulations to prevent duplicative charges to capital account for certain research and development expenditures

Transfers of intangible property to United States shareholders

September 16, 2026

Mr. Estes introduced the following bill; which was referred to the Committee on Ways and Means

A BILL

To amend the Internal Revenue Code of 1986 to modify certain provisions relating to the taxation of international entities.

1. Short title, etc; 2. Modification of deduction for foreign-derived intangible income and net controlled foreign corporation tested income; 3. Modifications to base erosion minimum tax; 4. Modification of foreign tax credit limitation baskets; 5. Carryover of net CFC tested loss; 6. Redetermination of foreign taxes and related claims; 7. Repeal of foreign tax credit haircut for net controlled foreign corporation tested income; 8. Repeal of inclusion percentage applicable to deemed paid credit for taxes properly attributable to tested income; 9. Application of foreign-source dividend deduction to amounts received by controlled foreign corporations; 10. Elimination of inclusion of foreign base company sales income and foreign base company services income; 11. Corporations exempt from subpart F inclusion for investment in United States property; 12. Special rules for transfers of intangible property from controlled foreign corporations to United States shareholders; 13. Net CFC tested income determined without regard to certain income derived from services performed in the United States Virgin Islands; 14. Repeal of modification to definition of adjusted taxable income for purposes of the limitation on business interest; 15. Research credit treated as a specified credit for all taxpayers for purposes of general business credit; 16. Regulations to prevent duplicative charges to capital account for certain research and development expenditures

Transfers of intangible property to United States shareholders