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119-s-1605119th CongressWALLET

International Competition for American Jobs Act

Sponsored By: Senator Tillis, Thomas [R-NC]

Introduced

Summary

Recalibrates international tax rules for U.S. multinationals. This bill would rewrite how cross‑border income is measured and taxed across GILTI, FDII, Subpart F, the foreign tax credit, BEAT, and related mechanics.

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Bill Overview

Analyzed Economic Effects

3 provisions identified: 2 benefits, 0 costs, 1 mixed.

Lower BEAT exposure for multinationals

If enacted, the bill would change the base erosion and anti-abuse tax (BEAT). The BEAT minimum would be based on the taxpayer's regular tax. Companies could use general business credits against the BEAT. Payments to related foreign parties taxed at at least 18.9% would not count as base erosion payments if the taxpayer proves it. These changes would apply to tax years starting after December 31, 2025.

New international corporate tax formula

If enacted, this bill would change how U.S. corporations are allowed to deduct and report foreign income. It would replace the current deduction with one equal to 37.5% of foreign-derived deduction eligible income plus 50% of GILTI and the related section 78 amount. It would also change how GILTI is computed, how foreign taxes are credited, and how Subpart F and ownership tests work. These rules would generally apply to tax years starting after December 31, 2025.

Special rule for CFC intangible payouts

If enacted, the bill would create a special rule for certain intangible property distributions from a controlled foreign corporation (CFC) to a U.S. corporate shareholder. If the CFC distributes the intangible before the end of its third tax year beginning after December 31, 2025, the fair market value on distribution would be treated as not more than the adjusted basis for certain tax rules. If the distribution is not a dividend, the shareholder's stock basis would increase by the income that would otherwise be includible.

Sponsors & CoSponsors

Sponsor

Tillis, Thomas [R-NC]

NC • R

Cosponsors

There are no cosponsors for this bill.

Roll Call Votes

No roll call votes available for this bill.

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