S.2021

Close the Round-Tripping Loophole Act amends the Internal Revenue Code to exclude round-tripped income when calculating global intangible low-taxed.

The Close the Round-Tripping Loophole Act amends the Internal Revenue Code to exclude round-tripped income for purposes of calculating global intangible low-taxed income. This involves modifying the determination of net deemed intangible income return and limiting the deduction for global intangible low-taxed income. The changes apply to taxable years beginning after the date of enactment. The bill also introduces a round-tripping ratio to measure the extent of round-tripped income, with exceptions for certain small taxpayers.