# 119-s-2021: Close the Round-Tripping Loophole Act

119-s-2021, Close the Round-Tripping Loophole Act, is a 119th Congress bill sponsored by Sen. Wyden, Ron [D-OR] (D-OR); status introduced; PRIA reads it as touching household money (as of 2025-12-21).

- Canonical: https://policyrisk.com/legislation/119-s-2021
- As of: 2025-12-21
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Bill: 119-s-2021
- Congress: 119
- Title: Close the Round-Tripping Loophole Act
- Status: introduced
- Introduced: 2025-06-11
- Sponsor: Sen. Wyden, Ron [D-OR] (D-OR)
- Cosponsors: 3
- Policy area: Taxation
- Touches household money: yes
- Last recorded action: 2025-12-21

## Summary

**This bill would _curb round‑tripping that reduces United States tax on offshore profits_.** It adds a new "round‑tripping ratio" to the global intangible low‑taxed income (GILTI) calculation and cuts the Section 250 deduction in proportion to that ratio to shrink the tax advantage of routing earnings through controlled foreign corporations. - Large U.S. multinational companies: More foreign‑affiliate profits could be treated as GILTI under the new calculation, and the Section 250 deduction is limited so its benefit falls as the round‑tripping ratio rises. The deduction formula includes a 50 percent baseline that is reduced by the ratio. - Small U.S. shareholders and businesses: A 0 percent round‑tripping ratio applies to qualifying U.S. shareholders that meet a 3‑year average gross receipts test of at most $100 million, protecting their deduction from reduction. - Timing and scope: The changes apply to foreign corporations' taxable years beginning after enactment and to U.S. shareholder years that end with or include those foreign years. Section 3's deduction limit applies to taxable years beginning after enactment.

## Cosponsors (3)

- Sen. Warner, Mark R. [D-VA] (D-VA), 2025-06-11T00:00:00.000Z
- Sen. Warnock, Raphael G. [D-GA] (D-GA), 2025-06-11T00:00:00.000Z
- Sen. Welch, Peter [D-VT] (D-VT), 2025-06-11T00:00:00.000Z

## Provisions PRIA read

- Higher taxes on round-tripped foreign income: cost, high. If enacted, U.S. shareholders of foreign subsidiaries would get a yearly "round-tripping ratio." The ratio measures how much tested CFC income is treated as round-tripped and is capped at 100%. The bill would set the ratio to 0% for firms with average annual gross receipts of $100,000,000 or less (…

## Related bills

- 119-s-5066: Health Equity and Accountability Act of 2026
- 119-s-891: Bipartisan Health Care Act
- 119-s-3990: PrEP Access and Coverage Act of 2026
- 119-s-2763: Keep Billionaires Out of Social Security Act
- 119-s-51: Washington, D.C. Admission Act
- 119-s-5108: Right to IVF Act of 2026

## Sources
- [119-s-2021 on Congress.gov](https://www.congress.gov/bill/119th-congress/senate-bill/2021)

## Related
- [119-s-5066: Health Equity and Accountability Act of 2026](https://policyrisk.com/legislation/119-s-5066)
- [119-s-891: Bipartisan Health Care Act](https://policyrisk.com/legislation/119-s-891)
- [119-s-3990: PrEP Access and Coverage Act of 2026](https://policyrisk.com/legislation/119-s-3990)
- [119-s-2763: Keep Billionaires Out of Social Security Act](https://policyrisk.com/legislation/119-s-2763)
- [119-s-51: Washington, D.C. Admission Act](https://policyrisk.com/legislation/119-s-51)
- [119-s-5108: Right to IVF Act of 2026](https://policyrisk.com/legislation/119-s-5108)
- [All bills in Congress](https://policyrisk.com/legislation)

Source: PRIA, https://policyrisk.com/legislation/119-s-2021 (as of 2025-12-21).