# 119-hr-1911: To amend the Internal Revenue Code of 1986 to provide that certain payments to foreign related parties subject to sufficient foreign tax are not treated as base erosion payments.

119-hr-1911, To amend the Internal Revenue Code of 1986 to provide that certain payments to foreign related parties subject to sufficient foreign tax are not treated as base erosion payments., is a 119th Congress bill sponsored by Rep. Conaway, Herbert C. [D-NJ-3] (D-NJ); status introduced; PRIA reads it as touching household money (as of 2025-12-21).

- Canonical: https://policyrisk.com/legislation/119-hr-1911
- As of: 2025-12-21
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Bill: 119-hr-1911
- Congress: 119
- Title: To amend the Internal Revenue Code of 1986 to provide that certain payments to foreign related parties subject to sufficient foreign tax are not treated as base erosion payments.
- Status: introduced
- Introduced: 2025-03-06
- Sponsor: Rep. Conaway, Herbert C. [D-NJ-3] (D-NJ)
- Cosponsors: 2
- Policy area: Taxation
- Touches household money: yes
- Last recorded action: 2025-12-21

## Summary

**Creates a 15% effective foreign tax safe harbor** that would keep certain cross-border payments to related foreign parties from being treated as base erosion payments under Section 59A of the Internal Revenue Code. The safe harbor would require both the foreign recipient and the payment itself to face an effective foreign income tax rate of at least 15 percent and would set rules for measuring that rate from financial statements with specified adjustments. - Multinational companies would be able to avoid base erosion treatment for qualifying payments if the recipient and the payment meet a 15% effective foreign tax test, giving a clearer path for compliance. - Foreign affiliates would need to be taxed at an effective rate of at least 15% for payments to qualify, using applicable financial statements with adjustments for items like excluded dividends, large penalties, prior period errors, pension accruals, and illegal payments. - The Treasury would get authority to write regulations to define the effective rate, list required adjustments, and add anti‑abuse rules such as recharacterizing related‑party transactions. - These rules would apply to taxable years beginning after enactment, creating a new test firms must meet to avoid base erosion rules.

## Cosponsors (2)

- Rep. Suozzi, Thomas R. [D-NY-3] (D-NY), 2025-03-06T00:00:00.000Z
- Rep. Van Drew, Jefferson [R-NJ-2] (R-NJ), 2025-03-06T00:00:00.000Z

## Provisions PRIA read

- Business tax safe harbor on foreign payments: benefit, medium. If enacted, some payments your company makes to a related foreign affiliate would not count as base erosion payments. To qualify, both the foreign affiliate and the specific payment would need at least a 15% effective foreign income tax rate. You would need to show this using applicable financial s…

## Related bills

- 119-hr-7977: Energy Bills Relief Act
- 119-hr-7481: Department of Homeland Security Appropriations Act, 2026
- 119-hr-7973: Momnibus Act
- 119-hr-2086: Rights for the TSA Workforce Act
- 119-hr-4669: FEMA Act of 2025
- 119-hr-3151: SHIPS for America Act of 2025

## Sources
- [119-hr-1911 on Congress.gov](https://www.congress.gov/bill/119th-congress/house-bill/1911)

## Related
- [119-hr-7977: Energy Bills Relief Act](https://policyrisk.com/legislation/119-hr-7977)
- [119-hr-7481: Department of Homeland Security Appropriations Act, 2026](https://policyrisk.com/legislation/119-hr-7481)
- [119-hr-7973: Momnibus Act](https://policyrisk.com/legislation/119-hr-7973)
- [119-hr-2086: Rights for the TSA Workforce Act](https://policyrisk.com/legislation/119-hr-2086)
- [119-hr-4669: FEMA Act of 2025](https://policyrisk.com/legislation/119-hr-4669)
- [119-hr-3151: SHIPS for America Act of 2025](https://policyrisk.com/legislation/119-hr-3151)
- [All bills in Congress](https://policyrisk.com/legislation)

Source: PRIA, https://policyrisk.com/legislation/119-hr-1911 (as of 2025-12-21).