This bill amends the Internal Revenue Code to modify the base erosion and anti-abuse tax (BEAT) for certain entities connected to jurisdictions that impose an extraterritorial tax. It targets foreign-owned entities in such jurisdictions with stricter rules.
Sec. 2, Application of the base erosion and anti-abuse tax with respect to certain entities connected to extraterritorial tax jurisdictions: This section adds new rules for 'foreign-owned extraterritorial tax regime entities.' For such entities, they are automatically treated as applicable taxpayers under the BEAT, the effective date for certain BEAT provisions is set to the enactment date of this subsection, certain exceptions to BEAT calculations do not apply, and 50% of their cost of goods sold is treated as a base erosion tax benefit. A 'foreign-owned extraterritorial tax regime entity' is defined as a taxpayer controlled by a foreign entity (not controlled by a U.S. corporation) if an extraterritorial tax is imposed on that controlling foreign entity or related entities. An 'extraterritorial tax' is a foreign tax on a corporation based on income received by any person connected through ownership, excluding individual ownership interests. The amendment applies to taxable years beginning after the enactment date.
Summary of the bill text as introduced in House (Mar 27, 2025), generated by SecBot from the official bill text; the Library of Congress summary is not yet published.
Actions
HouseIntroduced in HouseMar 27, 2025
HouseReferred to the House Committee on Ways and Means.Mar 27, 2025
House Ways and Means CommitteeReferred To Mar 27, 2025
Sponsor and cosponsors24 cosponsors
Rep. Ron Estes (R-KS-4)Sponsor, Mar 27, 2025
Aaron Bean (R-FL-4)OriginalJoined Mar 27, 2025
Adrian Smith (R-NE-3)OriginalJoined Mar 27, 2025
Beth Van Duyne (R-TX-24)OriginalJoined Mar 27, 2025
Blake Moore (R-UT-1)OriginalJoined Mar 27, 2025
Brian Fitzpatrick (R-PA-1)OriginalJoined Mar 27, 2025
Carol Miller (R-WV-1)OriginalJoined Mar 27, 2025
Claudia Tenney (R-NY-24)OriginalJoined Mar 27, 2025
Darin LaHood (R-IL-16)OriginalJoined Mar 27, 2025
David Kustoff (R-TN-8)OriginalJoined Mar 27, 2025
David Schweikert (R-AZ-1)OriginalJoined Mar 27, 2025
Gregory Murphy (R-NC-3)OriginalJoined Mar 27, 2025
Jodey Arrington (R-TX-19)OriginalJoined Mar 27, 2025
Kevin Hern (R-OK-1)OriginalJoined Mar 27, 2025
Lloyd Smucker (R-PA-11)OriginalJoined Mar 27, 2025
Max Miller (R-OH-7)OriginalJoined Mar 27, 2025
Michelle Fischbach (R-MN-7)OriginalJoined Mar 27, 2025
Mike Carey (R-OH-15)OriginalJoined Mar 27, 2025
Mike Kelly (R-PA-16)OriginalJoined Mar 27, 2025
Nathaniel Moran (R-TX-1)OriginalJoined Mar 27, 2025
Nicole Malliotakis (R-NY-11)OriginalJoined Mar 27, 2025
Randy Feenstra (R-IA-4)OriginalJoined Mar 27, 2025
Rudy Yakym (R-IN-2)OriginalJoined Mar 27, 2025
Vern Buchanan (R-FL-16)OriginalJoined Mar 27, 2025
W. Steube (R-FL-17)OriginalJoined Mar 27, 2025
Amendments0
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Titles2
Short titles
Unfair Tax Prevention ActShort Title(s) as Introduced
Official titles
To amend the Internal Revenue Code of 1986 to modify the application of the base erosion and anti-abuse tax with respect to certain entities connected to jurisdictions which have implemented an extraterritorial tax.Official Title as Introduced