II 

117TH CONGRESS 

2D SESSION S. 5349 

To amend the Internal Revenue Code of 1986 to modify certain provisions 

relating to the taxation of international entities. 

IN THE SENATE OF THE UNITED STATES 

DECEMBER 21, 2022 

Mr. PORTMAN introduced the following bill; which was read twice and referred 

to the Committee on Finance 

A BILL 

To amend the Internal Revenue Code of 1986 to modify 

certain provisions relating to the taxation of international 

entities. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE, ETC. 

4 (a) SHORT TITLE.—This Act may be cited as the 

5 ‘‘International Competition for American Jobs Act’’. 

6 (b) AMENDMENT OF 1986 CODE.—Except as other7 wise expressly provided, whenever in this Act an amend8 ment or repeal is expressed in terms of an amendment 

9 to, or repeal of, a section or other provision, the reference 


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1 shall be considered to be made to a section or other provi2 sion of the Internal Revenue Code of 1986. 

3 SEC. 2. PERMANENT EXTENSION OF LOOK-THRU RULE FOR 

4 CONTROLLED FOREIGN CORPORATIONS. 

5 (a) IN GENERAL.—Section 954(c)(6)(C) is amended 

6 by striking ‘‘and before January 1, 2026,’’. 

7 (b) EFFECTIVE DATE.—The amendment made by 

8 this section shall apply to taxable years of foreign corpora9 tions beginning after December 31, 2022, and to taxable 

10 years of United States shareholders with or within which 

11 such taxable years of foreign corporations end. 

12 SEC. 3. MODIFICATION OF DEDUCTION FOR FOREIGN-DE13 RIVED INTANGIBLE INCOME AND GLOBAL IN14 TANGIBLE LOW-TAXED INCOME. 

15 (a) IN GENERAL.—Section 250(a) is amended to 

16 read as follows: 

17 ‘‘(a) ALLOWANCE OF DEDUCTION.—In the case of a 

18 domestic corporation for any taxable year, there shall be 

19 allowed as a deduction an amount equal to the sum of— 

20 ‘‘(1) 37.5 percent of the foreign-derived intan21 gible income of such domestic corporation for such 

22 taxable year, plus 

23 ‘‘(2) 50 percent of— 

24 ‘‘(A) the global intangible low-taxed income 

25 amount (if any) which is included in the gross 


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1 income of such domestic corporation under sec2 tion 951A for such taxable year, and 

3 ‘‘(B) the amount treated as a dividend re4 ceived by such corporation under section 78 

5 which is attributable to the amount described in 

6 subparagraph (A).’’. 

7 (b) DEDUCTION TAKEN INTO ACCOUNT IN DETER8 MINING NET OPERATING LOSS DEDUCTION.—Section 

9 172(d) is amended by striking paragraph (9). 

10 (c) EFFECTIVE DATE.—The amendments made by 

11 this section shall apply to taxable years beginning after 

12 December 31, 2022. 

13 SEC. 4. MODIFICATIONS TO BASE EROSION MINIMUM TAX. 

14 (a) BASE EROSION MINIMUM TAX AMOUNT DETER15 MINED WITHOUT REGARD TO CREDITS.— 

16 (1) IN GENERAL.—Section 59A(b)(1)(B) is 

17 amended to read as follows: 

18 ‘‘(B) an amount equal to the regular tax li19 ability (as defined in section 26(b)) of the tax20 payer for the taxable year.’’. 

21 (2) CONFORMING AMENDMENT.—Section 

22 59A(b) is amended by striking paragraph (4). 

23 (b) ELIMINATION OF MODIFICATIONS FOR TAXABLE

24 YEARS AFTER 2025.— 


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1 (1) IN GENERAL.—Section 59A(b) is amended 

2 by striking paragraph (2) and redesignating para3 graph (3) as paragraph (2). 

4 (2) CONFORMING AMENDMENTS.— 

5 (A) Section 59A(b)(1) is amended by strik6 ing ‘‘paragraphs (2) and (3)’’ and inserting 

7 ‘‘paragraph (2)’’. 

8 (B) Paragraph (2) of section 59A(b), as 

9 redesignated by paragraph (1), is amended by 

10 striking ‘‘under paragraphs (1)(A) and (2)(A) 

11 shall each be increased’’ and inserting ‘‘under 

12 paragraph (1)(A) shall be increased’’. 

13 (C) Section 59A(e)(1)(C) is amended by 

14 striking ‘‘subsection (b)(3)(B)’’ and inserting 

15 ‘‘subsection (b)(2)(B)’’. 

16 (c) EXPANSION AND CONSOLIDATION OF RULES TO

17 EXEMPT CERTAIN PAYMENTS FROM TREATMENT AS

18 BASE EROSION PAYMENTS.— 

19 (1) IN GENERAL.—Section 59A is amended by 

20 redesignating subsection (i) as subsection (j) and by 

21 inserting after subsection (h) the following new sub22 section: 

23 ‘‘(i) CERTAIN PAYMENT NOT TREATED AS BASE

24 EROSION PAYMENTS.— 


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1 ‘‘(1) EXCEPTION FOR PAYMENTS ON WHICH

2 TAX IS IMPOSED.— 

3 ‘‘(A) IN GENERAL.—An amount shall not 

4 be treated as a base erosion payment if tax is 

5 (or was at the time of payment or accrual) im6 posed by this chapter with respect to such 

7 amount (other than by this section). 

8 ‘‘(B) TREATMENT OF CERTAIN DEDUC9 TIONS.—For purposes of subparagraph (A), tax 

10 shall be treated as imposed by this chapter 

11 without regard to any deduction allowed under 

12 part VIII of subchapter B. 

13 ‘‘(C) APPLICATION OF CERTAIN RULES.— 

14 The amount not treated as a base erosion pay15 ment by reason of this paragraph shall be de16 termined under rules similar to the rules of sec17 tion 163(j)(5) (as in effect before the date of 

18 the enactment of Public Law 115–97). 

19 ‘‘(2) EXCEPTION FOR CERTAIN PAYMENTS SUB20 JECT TO SUFFICIENT FOREIGN TAX.— 

21 ‘‘(A) IN GENERAL.—An amount shall not 

22 be treated as a base erosion payment if the tax23 payer establishes to the satisfaction of the Sec24 retary that such amount was made to a foreign 

25 person which is a related party of the taxpayer 


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1 that is subject to an effective rate of foreign in2 come tax (as defined in section 904(d)(2)(F)) 

3 which is not less than 18.9 percent. 

4 ‘‘(B) CERTAIN PAYMENTS TO RELATED

5 PARTIES.—To the extent provided by the Sec6 retary in regulations, an amount paid to a for7 eign person which is a related party of the tax8 payer shall be treated as paid to another for9 eign person which is a related party of the tax10 payer if such second foreign person is subject to 

11 an effective rate of foreign income tax (as de12 fined in section 904(d)(2)(F)) which is less 

13 than 18.9 percent, to the extent the amount so 

14 paid directly or indirectly funds a payment to 

15 such second foreign person. 

16 ‘‘(C) DETERMINATION ON BASIS OF APPLI17 CABLE FINANCIAL STATEMENTS.—Except as 

18 otherwise provided by the Secretary under sub19 paragraph (D), the effective rate of foreign in20 come tax with respect to any amount may be 

21 established on the basis of applicable financial 

22 statements (as defined in section 451(b)(3)). 

23 ‘‘(D) REGULATIONS.—The Secretary shall 

24 issue such regulations or other guidance as may 

25 be necessary or appropriate to carry out the 


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1 purposes of this paragraph, including regula2 tions or other guidance providing procedures for 

3 determining the effective rate of foreign income 

4 tax to which any amount is subject. Such proce5 dures may require that any transaction or se6 ries of transactions among multiple parties be 

7 recharacterized as one or more transactions di8 rectly among any 2 or more of such parties 

9 where the Secretary determines that such re10 characterization is appropriate to carry out, or 

11 prevent avoidance of, the purposes of this sec12 tion. 

13 ‘‘(3) EXCEPTION FOR CERTAIN AMOUNTS WITH

14 RESPECT TO SERVICES.—Subsections (d)(1) and 

15 (d)(2) shall not apply to so much of any amount 

16 paid or accrued by a taxpayer for services as does 

17 not exceed the total services cost of such services. 

18 The preceding sentence shall not apply unless such 

19 services meet the requirements for eligibility for use 

20 of the services cost method under section 482 (deter21 mined without regard to the requirement that the 

22 services not contribute significantly to fundamental 

23 risks of business success or failure).’’. 

24 (2) CONFORMING AMENDMENT.—Section 

25 59A(d) is amended by striking paragraph (5). 


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1 (d) OTHER MODIFICATIONS.— 

2 (1) Section 59A(b)(3)(B)(ii) is amended by 

3 striking ‘‘registered securities dealer’’ and inserting 

4 ‘‘securities dealer registered’’. 

5 (2) Section 59A(h)(2)(B) is amended by strik6 ing ‘‘section 6038B(b)(2)’’ and inserting ‘‘section 

7 6038A(b)(2)’’. 

8 (3) Section 59A(j)(2), as redesignated by sub9 section (b), is amended by striking ‘‘subsection 

10 (g)(3)’’ and inserting ‘‘subsection (h)(3)’’. 

11 (e) EFFECTIVE DATE.—The amendments made by 

12 this section shall apply to taxable years beginning after 

13 December 31, 2022. 

14 SEC. 5. RULES FOR ALLOCATION OF CERTAIN DEDUCTIONS 

15 TO FOREIGN SOURCE GLOBAL INTANGIBLE 

16 LOW-TAXED INCOME FOR PURPOSES OF FOR17 EIGN TAX CREDIT LIMITATION. 

18 (a) IN GENERAL.—Section 904(b) is amended by 

19 adding at the end the following new paragraph: 

20 ‘‘(5) DEDUCTIONS TREATED AS ALLOCABLE TO

21 FOREIGN SOURCE GLOBAL INTANGIBLE LOW-TAXED

22 INCOME.—In the case of a domestic corporation and 

23 solely for purposes of the application of subsection 

24 (a) with respect to amounts described in subsection 

25 (d)(1)(A), the taxpayer’s taxable income from 


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1 sources without the United States shall be deter2 mined— 

3 ‘‘(A) by allocating and apportioning any 

4 deduction allowed under section 250(a)(2) (and 

5 any deduction allowed under section 164(a)(3) 

6 for taxes imposed on amounts described in sec7 tion 250(a)(2)) to such income, and 

8 ‘‘(B) by allocating and apportioning any 

9 other deduction to such income only if the Sec10 retary determines that such deduction is di11 rectly allocable to such income. 

12 Any deduction which would (but for subparagraph 

13 (B)) have been allocated or apportioned to such in14 come shall only be allocated or apportioned to in15 come which is from sources within the United 

16 States.’’. 

17 (b) APPLICATION OF SEPARATE LIMITATION LOSSES

18 WITH RESPECT TO GLOBAL INTANGIBLE LOW-TAXED IN19 COME.— 

20 (1) IN GENERAL.—Section 904(f)(5)(B) is 

21 amended to read as follows: 

22 ‘‘(B) ALLOCATION OF LOSSES.—Except as 

23 otherwise provided in this subparagraph, the 

24 separate limitation losses for any taxable year 

25 (to the extent such losses do not exceed the sepVerDate Sep 11 2014 02:49 Jan 08, 2023 Jkt 039200 PO 00000 Frm 00009 Fmt 6652 Sfmt 6201 E:\BILLS\S5349.IS S5349

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1 arate limitation incomes for such year) shall be 

2 allocated among (and operate to reduce) such 

3 incomes on a proportionate basis. In the case of 

4 a separate limitation loss for any taxable year 

5 in any category other than subparagraph 

6 (d)(1)(A), the amount of such separate limita7 tion loss shall be allocated among (and operate 

8 to reduce) separate limitation income in any 

9 category other than income described in sub10 paragraph (d)(1)(A) on a proportionate basis 

11 (without regard to income described in subpara12 graph (d)(1)(A)). The remaining separate limi13 tation losses may reduce separate limitation in14 come described in subparagraph (d)(1)(A) only 

15 to the extent that the aggregate amount of such 

16 losses exceeds the aggregate amount of separate 

17 limitation incomes (other than income described 

18 in subparagraph (d)(1)(A)) for such taxable 

19 year.’’. 

20 (2) INCOME CATEGORY.—Section 

21 904(f)(5)(E)(i) is amended to read as follows: 

22 ‘‘(i) INCOME CATEGORY.—The term 

23 ‘income category’ means each category of 

24 income with respect to which this section is 


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1 required to be applied separately by reason 

2 of any provision of this title.’’. 

3 (3) SEPARATE LIMITATION LOSS.—Section 

4 904(f)(5)(E)(iii) is amended to read as follows: 

5 ‘‘(iii) SEPARATE LIMITATION LOSS.— 

6 The term ‘separate limitation loss’ means, 

7 with respect to any income category, the 

8 amount by which the gross income from 

9 sources outside the United States is ex10 ceeded by the sum of the deductions prop11 erly allocated and apportioned thereto.’’. 

12 (c) APPLICATION OF CARRYFORWARD TO TAXES ON

13 GLOBAL INTANGIBLE LOW-TAXED INCOME.—Section 

14 904(c) is amended by striking the last sentence. 

15 (d) EFFECTIVE DATE.— 

16 (1) IN GENERAL.—Except as provided in para17 graph (2), the amendments made by this section 

18 shall apply to taxable years beginning after Decem19 ber 31, 2022. 

20 (2) MODIFICATION OF FOREIGN TAX CREDIT

21 CARRYBACK AND CARRYFORWARD.—The amendment 

22 made by subsection (c) shall apply to taxes paid or 

23 accrued in taxable years beginning after December 

24 31, 2022. 


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1 SEC. 6. RESTORATION OF LIMITATION ON DOWNWARD AT2 TRIBUTION OF STOCK OWNERSHIP IN APPLY3 ING CONSTRUCTIVE OWNERSHIP RULES. 

4 (a) IN GENERAL.—Section 958(b) is amended— 

5 (1) by inserting after paragraph (3) the fol6 lowing: 

7 ‘‘(4) Subparagraphs (A), (B), and (C) of sec8 tion 318(a)(3) shall not be applied so as to consider 

9 a United States person as owning stock which is 

10 owned by a person who is not a United States per11 son.’’, and 

12 (2) by striking ‘‘Paragraph (1)’’ in the last sen13 tence and inserting ‘‘Paragraphs (1) and (4)’’. 

14 (b) FOREIGN CONTROLLED UNITED STATES SHARE15 HOLDERS.—Subpart F of part III of subchapter N of 

16 chapter 1 is amended by inserting after section 951A the 

17 following new section: 

18 ‘‘SEC. 951B. AMOUNTS INCLUDED IN GROSS INCOME OF 

19 FOREIGN CONTROLLED UNITED STATES 

20 SHAREHOLDERS. 

21 ‘‘(a) IN GENERAL.—In the case of any foreign con22 trolled United States shareholder of a foreign controlled 

23 foreign corporation— 

24 ‘‘(1) this subpart (other than sections 951A, 

25 951(b), and 957) shall be applied with respect to 

26 such shareholder (separately from, and in addition 


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1 to, the application of this subpart without regard to 

2 this section)— 

3 ‘‘(A) by substituting ‘foreign controlled 

4 United States shareholder’ for ‘United States 

5 shareholder’ each place it appears therein, and 

6 ‘‘(B) by substituting ‘foreign controlled 

7 foreign corporation’ for ‘controlled foreign cor8 poration’ each place it appears therein, and 

9 ‘‘(2) section 951A shall be applied with respect 

10 to such shareholder— 

11 ‘‘(A) by treating each reference to ‘United 

12 States shareholder’ in such section as including 

13 a reference to such shareholder, and 

14 ‘‘(B) by treating each reference to ‘con15 trolled foreign corporation’ in such section as 

16 including a reference to such foreign controlled 

17 foreign corporation. 

18 ‘‘(b) FOREIGN CONTROLLED UNITED STATES

19 SHAREHOLDER.—For purposes of this section, the term 

20 ‘foreign controlled United States shareholder’ means, with 

21 respect to any foreign corporation, any United States per22 son which would be a United States shareholder with re23 spect to such foreign corporation if— 

24 ‘‘(1) section 951(b) were applied by substituting 

25 ‘more than 50 percent’ for ‘10 percent or more’, and 


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1 ‘‘(2) section 958(b) were applied without regard 

2 to paragraph (4) thereof. 

3 ‘‘(c) FOREIGN CONTROLLED FOREIGN CORPORA4 TION.—For purposes of this section, the term ‘foreign con5 trolled foreign corporation’ means a foreign corporation, 

6 other than a controlled foreign corporation, which would 

7 be a controlled foreign corporation if section 957(a) were 

8 applied— 

9 ‘‘(1) by substituting ‘foreign controlled United 

10 States shareholders’ for ‘United States share11 holders’, and 

12 ‘‘(2) by substituting ‘section 958(b) (other than 

13 paragraph (4) thereof)’ for ‘section 958(b)’. 

14 ‘‘(d) REGULATIONS.—The Secretary shall prescribe 

15 such regulations or other guidance as may be necessary 

16 or appropriate to carry out the purposes of this section, 

17 including regulations or other guidance— 

18 ‘‘(1) to treat a foreign controlled United States 

19 shareholder or a foreign controlled foreign corpora20 tion as a United States shareholder or as a con21 trolled foreign corporation, respectively, for purposes 

22 of provisions of this title other than this subpart, 

23 and 

24 ‘‘(2) to prevent the avoidance of the purposes of 

25 this section.’’. 


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1 (c) CLERICAL AMENDMENT.—The table of sections 

2 for subpart F of part III of subchapter N of chapter 1 

3 is amended by inserting after the item relating to section 

4 951A the following new item: 

‘‘Sec. 951B. Amounts included in gross income of foreign controlled United 

States shareholders.’’. 

5 (d) EFFECTIVE DATE.—The amendments made by 

6 this section shall apply to— 

7 (1) the last taxable year of foreign corporations 

8 beginning before January 1, 2023, and each subse9 quent taxable year of such foreign corporations, and 

10 (2) taxable years of United States persons in 

11 which or with which such taxable years of foreign 

12 corporations end. 

13 (e) NO INFERENCE.—The amendments made by this 

14 section shall not be construed to create any inference with 

15 respect to the proper application of any provision of the 

16 Internal Revenue Code of 1986 with respect to taxable 

17 years beginning before the taxable years to which such 

18 amendments apply. 

19 SEC. 7. CARRYOVER OF NET CFC TESTED LOSS. 

20 (a) IN GENERAL.—Section 951A(c) is amended by 

21 adding at the end the following new paragraph: 

22 ‘‘(3) CARRYOVER OF NET CFC TESTED LOSS.— 

23 ‘‘(A) IN GENERAL.—If the amount de24 scribed in paragraph (1)(B) with respect to any 


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1 United States shareholder for any taxable year 

2 of such United States shareholder (determined 

3 after the application of this paragraph with re4 spect to amounts arising in preceding taxable 

5 years) exceeds the amount described in para6 graph (1)(A) with respect to such shareholder 

7 of such taxable year, the amount otherwise de8 scribed in paragraph (1)(B) with respect to 

9 such shareholder for the succeeding taxable 

10 year shall be increased by the amount of such 

11 excess. 

12 ‘‘(B) PROPER ADJUSTMENT IN ALLOCA13 TIONS OF GLOBAL INTANGIBLE LOW-TAXED IN14 COME TO CONTROLLED FOREIGN CORPORA15 TIONS.—Proper adjustments shall be made in 

16 the application of subsection (f)(2)(B) to take 

17 into account any decrease in global intangible 

18 low-taxed income by reason of the application of 

19 subparagraph (A).’’. 

20 (b) APPLICATION OF RULES WITH RESPECT TO

21 OWNERSHIP CHANGES.—Section 382(d) is amended by 

22 adding at the end the following new paragraph: 

23 ‘‘(4) APPLICATION TO CARRYOVER OF NET CFC

24 TESTED LOSS.—The term ‘pre-change loss’ shall in25 clude any excess carried over under section 


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1 951A(c)(3) under rules similar to the rules of para2 graph (1).’’. 

3 (c) EFFECTIVE DATE.—The amendments made by 

4 this section shall apply to taxable years of foreign corpora5 tions beginning after December 31, 2022, and to taxable 

6 years of United States shareholders in which or with which 

7 such taxable years of foreign corporations end. 

8 SEC. 8. REDETERMINATION OF FOREIGN TAXES AND RE9 LATED CLAIMS. 

10 (a) IN GENERAL.—Section 905(c) is amended— 

11 (1) in paragraph (1), by striking ‘‘or’’ at the 

12 end of subparagraph (B) and by inserting after sub13 paragraph (C) the following new subparagraphs: 

14 ‘‘(D) the taxpayer makes a timely change 

15 in its choice to claim a credit or deduction for 

16 taxes paid or accrued, or 

17 ‘‘(E) there is any other change in the 

18 amount, or treatment, of taxes, which affects 

19 the taxpayer’s tax liability under this chapter,’’, 

20 (2) in paragraph (2)(B)(i), by inserting ‘‘, ex21 cept as otherwise provided by the Secretary,’’ after 

22 ‘‘shall’’, and 

23 (3) by striking ‘‘ACCRUED’’ in the heading 

24 thereof. 


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1 (b) MODIFICATION TO TIME FOR CLAIMING CREDIT

2 OR DEDUCTION.—Section 901(a) is amended by striking 

3 the second sentence and inserting the following: ‘‘Such 

4 choice for any taxable year may be made or changed at 

5 any time before the expiration of the applicable period pre6 scribed by section 6511 for making a claim for credit or 

7 refund of an overpayment of the tax imposed by this chap8 ter for such taxable year that is attributable to such 

9 amounts.’’. 

10 (c) MODIFICATION TO SPECIAL PERIOD OF LIMITA11 TION.—Section 6511(d)(3) is amended— 

12 (1) in subparagraph (A)— 

13 (A) by inserting ‘‘a change in the liability 

14 for’’ before ‘‘any taxes paid or accrued’’, 

15 (B) by striking ‘‘actually paid’’ and insert16 ing ‘‘paid (or deemed paid under section 960)’’, 

17 and 

18 (C) by inserting ‘‘CHANGE IN THE LIABIL19 ITY FOR’’ before ‘‘FOREIGN TAXES’’ in the head20 ing thereof, and 

21 (2) in subparagraph (B), by striking ‘‘the allow22 ance of a credit for the taxes’’ and inserting ‘‘the al23 lowance of an additional credit by reason of the 

24 change in liability for the taxes’’. 

25 (d) EFFECTIVE DATE.— 


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1 (1) IN GENERAL.—Except as otherwise pro2 vided in this subsection, the amendments made by 

3 this section shall apply to taxes paid or accrued in 

4 taxable years beginning after December 31, 2022. 

5 (2) CERTAIN CHANGES.—The amendments 

6 made by paragraphs (1) and (3) of subsection (a) 

7 shall apply to changes that occur on or after the 

8 date which is 60 days after the date of the enact9 ment of this Act. 

10 (3) MODIFICATION TO SPECIAL PERIOD OF LIM11 ITATION.—The amendments made by subsection (c) 

12 shall apply to taxes paid, accrued, or deemed paid 

13 in taxable years beginning after December 31, 2022. 

Æ 


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