PRIA Logo™
119-hr-2423119th CongressWALLET

Unfair Tax Prevention Act

Sponsored By: Representative Estes, Ron [R-KS-4]

Introduced

Summary

This bill would revise the Base Erosion and Anti‑Abuse Tax (BEAT) to treat foreign‑owned extraterritorial tax regime entities differently in U.S. tax tests. It would count 50% of those entities' cost of goods sold as a base erosion tax benefit when determining BEAT exposure.

Show full summary
  • Corporations that meet the bill's new definition of a foreign‑owned extraterritorial tax regime entity would be pulled into BEAT calculations by treating part of their cost of goods sold as base erosion payments.
  • The bill carves out certain BEAT rules for these entities by making subsections (c)(2)(B), (c)(4)(B)(ii), and (d)(5) inapplicable, and it applies specific BEAT testing references from subsection (e)(1).
  • It defines key terms including "extraterritorial tax" to cover foreign taxes tied to income through ownership chains, and it sets the rules to apply to taxable years beginning after enactment and replaces a Dec. 31, 2025 cutoff with the enactment date.

Personalized for You

How does this bill affect your finances?

Personalize government policy and PRIA will tell you what this bill means for your household, plus every other piece of legislation we track. PRIA reads each provision against your financial profile to show you exactly what matters to your wallet.

Free to download

Bill Overview

Analyzed Economic Effects

1 provisions identified: 0 benefits, 1 costs, 0 mixed.

Higher taxes for some foreign-owned companies

This bill would set special rules under the Base Erosion and Anti‑Abuse Tax (BEAT) for some foreign‑owned companies. It would define these firms as ones controlled by a foreign entity and tied to a foreign “extraterritorial tax.” For those firms, 50% of their cost of goods sold would count as a base‑erosion tax benefit, which could raise BEAT tax. Some BEAT exceptions would not apply, and one timing rule would use the enactment date instead of December 31, 2025. These changes would apply to tax years starting after enactment.

Sponsors & CoSponsors

Sponsor

Estes, Ron [R-KS-4]

KS • R

Cosponsors

  • Rep. Buchanan, Vern [R-FL-16]

    FL • R

    Sponsored 3/27/2025

  • Rep. Smith, Adrian [R-NE-3]

    NE • R

    Sponsored 3/27/2025

  • Rep. Kelly, Mike [R-PA-16]

    PA • R

    Sponsored 3/27/2025

  • Rep. Schweikert, David [R-AZ-1]

    AZ • R

    Sponsored 3/27/2025

  • Rep. LaHood, Darin [R-IL-16]

    IL • R

    Sponsored 3/27/2025

  • Rep. Arrington, Jodey C. [R-TX-19]

    TX • R

    Sponsored 3/27/2025

  • Rep. Smucker, Lloyd [R-PA-11]

    PA • R

    Sponsored 3/27/2025

  • Rep. Hern, Kevin [R-OK-1]

    OK • R

    Sponsored 3/27/2025

  • Rep. Miller, Carol D. [R-WV-1]

    WV • R

    Sponsored 3/27/2025

  • Rep. Murphy, Gregory F. [R-NC-3]

    NC • R

    Sponsored 3/27/2025

  • Rep. Kustoff, David [R-TN-8]

    TN • R

    Sponsored 3/27/2025

  • Rep. Fitzpatrick, Brian K. [R-PA-1]

    PA • R

    Sponsored 3/27/2025

  • Rep. Steube, W. Gregory [R-FL-17]

    FL • R

    Sponsored 3/27/2025

  • Rep. Tenney, Claudia [R-NY-24]

    NY • R

    Sponsored 3/27/2025

  • Rep. Fischbach, Michelle [R-MN-7]

    MN • R

    Sponsored 3/27/2025

  • Rep. Moore, Blake D. [R-UT-1]

    UT • R

    Sponsored 3/27/2025

  • Rep. Van Duyne, Beth [R-TX-24]

    TX • R

    Sponsored 3/27/2025

  • Rep. Feenstra, Randy [R-IA-4]

    IA • R

    Sponsored 3/27/2025

  • Rep. Malliotakis, Nicole [R-NY-11]

    NY • R

    Sponsored 3/27/2025

  • Rep. Carey, Mike [R-OH-15]

    OH • R

    Sponsored 3/27/2025

  • Rep. Yakym, Rudy [R-IN-2]

    IN • R

    Sponsored 3/27/2025

  • Rep. Miller, Max L. [R-OH-7]

    OH • R

    Sponsored 3/27/2025

  • Rep. Bean, Aaron [R-FL-4]

    FL • R

    Sponsored 3/27/2025

  • Rep. Moran, Nathaniel [R-TX-1]

    TX • R

    Sponsored 3/27/2025

Roll Call Votes

No roll call votes available for this bill.

View on Congress.gov
Back to Legislation