The bill would change how certain foreign income is counted when calculating global intangible low-taxed income (GILTI), a category used in federal corporate tax rules. It creates a ratio based on income linked to property sold to a U.S. person, property not shown to be for foreign use, or services not shown to be for use outside the United States. The ratio would reduce parts of the GILTI calculation and related deduction. U.S. shareholders whose average annual gross receipts were $100 million or less over the prior three tax years would have a zero ratio. The changes would apply to tax years specified in the bill after enactment.
The changes mainly concern corporations with income from controlled foreign corporations. The bill does not describe direct effects on individual taxpayers.
The bill does not specify government spending. It changes how certain corporate income and deductions are calculated for tax purposes.
No publicly available information.
No publicly available information.