S. 409
Introduced in Senate · March 7, 2025February 5, 2025
Mr. Whitehouse (for himself, Mr. Durbin, Mr. Murphy, Mr. Reed, Ms. Baldwin, Ms. Warren, Mr. Merkley, Mr. Markey, Mr. Schatz, Mr. Fetterman, Mr. Blumenthal, Mr. Van Hollen, Mr. Gallego, Ms. Hirono, Mr. Heinrich, Mr. Booker, Ms. Smith, and Ms. Duckworth) introduced the following bill; which was read twice and referred to the Committee on Finance
A BILL
To amend the Internal Revenue Code of 1986 to provide for current year inclusion of net CFC tested income, and for other purposes.
1. Short title, etc; 2. Current year inclusion of net CFC tested income; 3. Country-by-country application of limitation on foreign tax credit based on taxable units; 4. Limitation on deduction of interest by domestic corporations which are members of an international financial reporting group; 5. Modifications to rules relating to inverted corporations; 6. Treatment of foreign corporations managed and controlled in the United States as domestic corporations
Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,