International Competition for American Jobs Act

Portman, Rob

International Competition for American Jobs Act This bill modifies provisions relating to the taxation of foreign entities. Among other provisions, the bill <ul> <li>makes permanent the look-thru rule for controlled foreign corporations (CFCs). (A look-thru rule provides that dividends, interest, rents and royalties that one CFC receives or accrues from a related CFC are not treated as foreign personal holding company income); </li> <li>modifies the tax deduction for foreign-derived intangible income and global intangible low-taxed income; </li> <li>modifies the base erosion minimum tax (10% minimum tax imposed to prevent corporations operating in the United States from avoiding tax liability by shifting profits out of the United States);</li> <li>modifies tax rules allocating certain tax deductions for purposes of the foreign tax credit limitation; </li> <li>restores the limitation on the attribution of stock ownership for purposes of applying constructive ownership rules; and </li> <li>includes specified amounts in the gross income of CFC shareholders.</li> </ul>