# 119-hr-10431: U.S. Innovation and Global Competitiveness Act of 2026

119-hr-10431, U.S. Innovation and Global Competitiveness Act of 2026, is a 119th Congress bill sponsored by Rep. Estes, Ron [R-KS-4] (R-KS); status introduced; PRIA reads it as touching household money (as of 2026-10-04).

- Canonical: https://policyrisk.com/legislation/119-hr-10431
- As of: 2026-10-04
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Bill: 119-hr-10431
- Congress: 119
- Title: U.S. Innovation and Global Competitiveness Act of 2026
- Status: introduced
- Introduced: 2026-09-16
- Sponsor: Rep. Estes, Ron [R-KS-4] (R-KS)
- Cosponsors: 0
- Policy area: Taxation
- Touches household money: yes
- Last recorded action: 2026-10-04

## Summary

**H.R. 10431 would deliver a comprehensive** overhaul of U.S. international corporate tax rules that boosts export‑related intangible income benefits, rewrites the BEAT base and exceptions, and remakes foreign tax credit and GILTI mechanics. - Domestic multinational corporations would see the Foreign‑Derived Intangible Income deduction rise from 33.34 percent to 40 percent. The bill also clarifies FDII interactions with the dividend‑received deduction and net operating losses and lets general business credits offset BEAT. - U.S. shareholders of controlled foreign corporations would get a carryover for net CFC tested losses and face reworked GILTI and deemed‑paid foreign tax credit rules, including repeal of the 90 percent FTC haircut and a reordering of FTC limitation baskets. - Tax administrators and territories would face broader Treasury rulemaking power, new triggers and elections for redeterminations of foreign taxes, narrowed Subpart F inclusions for sales and services income, a statutory mechanism to transfer intangibles from CFCs to U.S. shareholders, and adjusted treatment for U.S. Virgin Islands service income.

## Provisions PRIA read

- Changes to the BEAT minimum tax: mixed, high. If enacted, the BEAT minimum tax base would be redefined to equal a taxpayer's regular tax liability for the year. The bill would let Treasury issue rules to recharacterize multi‑party transactions and to implement exceptions. Several exceptions would remove certain payments from BEAT treatment, in…
- Fewer Subpart F inclusions for companies: mixed, high. If enacted, foreign base company sales income and services income would be removed from the Subpart F definition, so some CFC earnings would not be immediately included in U.S. taxable income. The bill would also restate who counts as a "related person" for Subpart F by using a more explicit contro…
- Lower taxes for U.S. exporters: mixed, high. If enacted, the FDII deduction rate for qualifying foreign‑derived income would rise from 33.34% to 40%, lowering taxable income for eligible U.S. exporters. The bill would add a look‑through rule so certain interest from a CFC to a related U.S. corporate shareholder can qualify as FDII‑eligible, a…
- More foreign tax relief for multinationals: mixed, high. If enacted, domestic corporations with GILTI inclusions would be treated as having paid their CFCs' foreign taxes in full, removing the prior 90% haircut. The bill would create a five‑year carryover for net CFC tested losses and let taxpayers adjust how those losses affect future tested income. It…

## Related bills

- 119-hr-4669: FEMA Act of 2025
- 119-hr-137: TCJA Permanency Act
- 119-hr-2725: Affordable Housing Credit Improvement Act of 2025
- 119-hr-1229: United States-Israel Defense Partnership Act of 2025
- 119-hr-624: RIFLE Act of 2025
- 119-hr-21: Born-Alive Abortion Survivors Protection Act

## Sources
- [119-hr-10431 on Congress.gov](https://www.congress.gov/bill/119th-congress/house-bill/10431)

## Related
- [119-hr-4669: FEMA Act of 2025](https://policyrisk.com/legislation/119-hr-4669)
- [119-hr-137: TCJA Permanency Act](https://policyrisk.com/legislation/119-hr-137)
- [119-hr-2725: Affordable Housing Credit Improvement Act of 2025](https://policyrisk.com/legislation/119-hr-2725)
- [119-hr-1229: United States-Israel Defense Partnership Act of 2025](https://policyrisk.com/legislation/119-hr-1229)
- [119-hr-624: RIFLE Act of 2025](https://policyrisk.com/legislation/119-hr-624)
- [119-hr-21: Born-Alive Abortion Survivors Protection Act](https://policyrisk.com/legislation/119-hr-21)
- [All bills in Congress](https://policyrisk.com/legislation)

Source: PRIA, https://policyrisk.com/legislation/119-hr-10431 (as of 2026-10-04).