Stop Corporate Inversions Act of 2026

Tighter inversion rules for multinationals

This bill would tighten U.S. tax rules for corporate inversions and affect multinational companies and their investors. It would apply to acquisitions completed after May 8, 2014 and to tax years ending after May 8, 2014. After such an acquisition, a foreign parent would be treated as an inverted domestic corporation if former U.S. owners hold more than 50% of the stock, or if management and control are mainly in the United States and the expanded group has significant U.S. business activity. The bill would count an expanded group's U.S. activity as "significant" if at least 25% of employees, employee pay, assets, or income are tied to the United States. It would also raise the surrogate foreign corporation test from 60% to 80% and let Treasury change these percent tests by regulation. An exception would keep the rule from applying if the group has substantial business activity in its foreign country as measured by rules in effect on January 18, 2017.