I 
118TH CONGRESS 
2D SESSION 
H. R. 8797 
To amend the Internal Revenue Code of 1986 to impose an income tax 
on excess profits of certain corporations. 
IN THE HOUSE OF REPRESENTATIVES 
JUNE 21, 2024 
Mr. BOWMAN (for himself, Ms. JAYAPAL, Ms. SCHAKOWSKY, and Ms. TLAIB) 
introduced the following bill; which was referred to the Committee on 
Ways and Means 
A BILL 
To amend the Internal Revenue Code of 1986 to impose 
an income tax on excess profits of certain corporations. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Ending Corporate 
Greed Act’’. 
SEC. 2. TAX ON EXCESS BUSINESS PROFITS OF CERTAIN 
CORPORATIONS. 
(a) IN GENERAL.—Subchapter A of chapter 1 of the 
Internal Revenue Code of 1986 is amended by adding at 
the end the following new part: 
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with respect to any taxable year, the taxable income of 
the taxpayer computed under this chapter for such taxable 
year, determined with the following modifications: 
‘‘(1) GLOBAL
INTANGIBLE
LOW-TAXED
IN-
COME.—In determining the amount of global intan-
gible low-taxed income included in income for the 
taxable year, the taxpayer’s net deemed tangible in-
come return for the taxable year under section 
951A(b)(1)(B) shall be zero. 
‘‘(2) DEDUCTIONS FOR FDII AND GILTI.—No 
deduction shall be allowed under section 250. 
‘‘(3) DEPRECIATION SYSTEM.—In the case of 
tangible property, the depreciation deduction allow-
able under section 167 shall be determined under 
the alternative depreciation system of section 
168(g). 
‘‘(4) RESEARCH
AND
EXPERIMENTAL
EX-
PENSES.—Section 174 shall be applied to amounts 
paid or incurred in any taxable year beginning on or 
before December 31, 2021, in the same manner as 
it is applied to amounts paid or incurred in taxable 
years beginning after such date. 
‘‘(5) DEDUCTIONS FOR EMPLOYEE REMUNERA-
TION.— 
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‘‘(A) IN GENERAL.—Section 162(m) shall 
be applied— 
‘‘(i) by substituting ‘covered individual 
(as defined in section 59B(d)(5)(B))’ for 
‘covered employee’ each place it appears in 
paragraphs (1) and (4) thereof, 
‘‘(ii) by treating any reference to an 
‘employee’ in paragraphs (1) and (4) 
thereof as a reference to an ‘individual’, 
and 
‘‘(iii) by substituting ‘was required to 
file reports under section 15(d) of such Act 
(15 U.S.C. 78o(d)) at any time during the 
3-taxable year period ending with the tax-
able year’ for ‘is required to file reports 
under section 15(d) of such Act (15 U.S.C. 
78o(d))’ in paragraph (2) thereof. 
‘‘(B) COVERED
INDIVIDUAL.—For pur-
poses of applying this paragraph to section 
162(m), the term ‘covered individual’ means 
any individual who performs services (directly 
or indirectly) for the taxpayer (or any prede-
cessor) for any taxable year beginning after De-
cember 31, 2023. 
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‘‘(e) APPLICABLE TAXPAYER.—For purposes of this 
section— 
‘‘(1) IN GENERAL.—The term ‘applicable tax-
payer’ means, with respect to any taxable year, a 
taxpayer— 
‘‘(A) which is a corporation other than a 
regulated investment company, a real estate in-
vestment trust, or an S corporation, and 
‘‘(B) the average annual gross receipts of 
which for the 3-taxable-year period ending with 
the preceding taxable year are at least 
$500,000,000. 
‘‘(2) GROSS RECEIPTS.— 
‘‘(A) SPECIAL
RULE
FOR
FOREIGN
PER-
SONS.—In the case of a foreign person the 
gross receipts of which are taken into account 
for purposes of paragraph (1)(B), only gross re-
ceipts which are taken into account in deter-
mining income which is effectively connected 
with the conduct of a trade or business within 
the United States shall be taken into account. 
In the case of a taxpayer which is a foreign per-
son, the preceding sentence shall not apply to 
the gross receipts of any United States person 
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which are aggregated with the taxpayer’s gross 
receipts by reason of paragraph (3). 
‘‘(B) OTHER RULES MADE APPLICABLE.— 
Rules similar to the rules of section 448(c)(3) 
shall apply in determining gross receipts for 
purposes of this section. 
‘‘(3) AGGREGATION RULES.—All persons treat-
ed as a single employer under subsection (a) of sec-
tion 52 shall be treated as 1 person for purposes of 
this subsection, except that in applying section 1563 
for purposes of section 52, the exception for foreign 
corporations under section 1563(b)(2)(C) shall be 
disregarded. 
‘‘(f) TERMINATION.—This section shall not apply to 
any taxable year beginning after December 31, 2026.’’. 
(b) CONFORMING AMENDMENT.—The table of sub-
chapters for subchapter A of chapter 1 of the Internal 
Revenue Code of 1986 is amended by adding at the end 
the following new item: 
‘‘PART VIII—EXCESS BUSINESS PROFITS’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
December 31, 2023. 
Æ 
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