ness activities constitute substantial business activi-
ties for purposes of this paragraph. 
‘‘(4) MANAGEMENT AND CONTROL.—For pur-
poses of paragraph (2)(B)(ii)— 
‘‘(A) IN
GENERAL.—The Secretary shall 
prescribe regulations for purposes of deter-
mining cases in which the management and 
control of an expanded affiliated group is to be 
treated as occurring, directly or indirectly, pri-
marily within the United States. The regula-
tions prescribed under the preceding sentence 
shall apply to periods after December 22, 2017. 
‘‘(B) EXECUTIVE OFFICERS AND SENIOR 
MANAGEMENT.—Such regulations shall provide 
that the management and control of an ex-
panded affiliated group shall be treated as oc-
curring, directly or indirectly, primarily within 
the United States if substantially all of the ex-
ecutive officers and senior management of the 
expanded affiliated group who exercise day-to- 
day responsibility for making decisions involving 
strategic, financial, and operational policies of 
the expanded affiliated group are based or pri-
marily located within the United States. Indi-
viduals who in fact exercise such day-to-day re-
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sponsibilities shall be treated as executive offi-
cers and senior management regardless of their 
title. 
‘‘(5) SIGNIFICANT DOMESTIC BUSINESS ACTIVI-
TIES.—For purposes of paragraph (2)(B)(ii), an ex-
panded affiliated group has significant domestic 
business activities if at least 25 percent of— 
‘‘(A) the employees of the group are based 
in the United States, 
‘‘(B) the employee compensation incurred 
by the group is incurred with respect to employ-
ees based in the United States, 
‘‘(C) the assets of the group are located in 
the United States, or 
‘‘(D) the income of the group is derived in 
the United States, 
determined in the same manner as such determina-
tions are made for purposes of determining substan-
tial business activities under regulations referred to 
in paragraph (3) as in effect on December 22, 2017, 
but applied by treating all references in such regula-
tions to ‘foreign country’ and ‘relevant foreign coun-
try’ as references to ‘the United States’. The Sec-
retary may issue regulations decreasing the thresh-
old percent in any of the tests under such regula-
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tions for determining if business activities constitute 
significant domestic business activities for purposes 
of this paragraph.’’. 
(b) CONFORMING AMENDMENTS.— 
(1) Clause (i) of section 7874(a)(2)(B) is 
amended by striking ‘‘after March 4, 2003,’’ and in-
serting ‘‘after March 4, 2003, and before December 
23, 2017,’’. 
(2) Subsection (c) of section 7874 is amend-
ed— 
(A) in paragraph (2)— 
(i) 
by 
striking 
‘‘subsection 
(a)(2)(B)(ii)’’ and inserting ‘‘subsections 
(a)(2)(B)(ii) and (b)(2)(B)(i)’’; and 
(ii) by inserting ‘‘or (b)(2)(A)’’ after 
‘‘(a)(2)(B)(i)’’ in subparagraph (B); 
(B) in paragraph (3), by inserting ‘‘or 
(b)(2)(B)(i), as the case may be,’’ after 
‘‘(a)(2)(B)(ii)’’; 
(C) in paragraph (5), by striking ‘‘sub-
section (a)(2)(B)(ii)’’ and inserting ‘‘sub-
sections (a)(2)(B)(ii) and (b)(2)(B)(i)’’; and 
(D) in paragraph (6), by inserting ‘‘or in-
verted domestic corporation, as the case may 
be,’’ after ‘‘surrogate foreign corporation’’. 
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(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years ending after De-
cember 22, 2017. 
SEC. 106. REQUIREMENT TO DISCLOSE TOTAL CORPORATE 
TAXES PAID. 
(a) IN GENERAL.—Section 13 of the Securities Ex-
change Act of 1934 (15 U.S.C. 78m) is amended by add-
ing at the end the following new subsection: 
‘‘(s) DISCLOSURE
OF TOTAL CORPORATE TAXES 
PAID.— 
‘‘(1) ISSUER
DISCLOSURE
REQUIREMENT.— 
Each issuer required to file an annual or quarterly 
report under subsection (a) shall disclose in that re-
port— 
‘‘(A) the total pre-tax profit of the issuer 
during the period covered by the report; 
‘‘(B) the total amount paid by the issuer 
in State taxes during the period covered by the 
report; 
‘‘(C) the total amount paid by the issuer in 
Federal taxes during the period covered by the 
report; and 
‘‘(D) the total amount paid by the issuer 
in foreign taxes during the period covered by 
the report. 
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‘‘(2) DISCLOSURE
OF
COUNTRY-BY-COUNTRY 
REPORTING INFORMATION.—Each issuer required to 
file an annual or quarterly report under subsection 
(a) shall disclose in that report, for each of its sub-
sidiaries and aggregated on a country-by-country 
basis— 
‘‘(A) revenues generated from transactions 
with other constituent entities; 
‘‘(B) revenues not generated from trans-
actions with other constituent entities; 
‘‘(C) profit or loss before income tax; 
‘‘(D) total income tax paid on a cash basis 
to all tax jurisdictions, and any taxes withheld 
on payments received by the constituent enti-
ties; 
‘‘(E) total accrued tax expense recorded on 
taxable profits or losses, reflecting only oper-
ations in the relevant annual period and exclud-
ing deferred taxes or provisions for uncertain 
tax liabilities; 
‘‘(F) stated capital, except that the stated 
capital of a permanent establishment must be 
reported in the tax jurisdiction of residence of 
the legal entity of which it is a permanent es-
tablishment unless there is a defined capital re-
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quirement in the permanent establishment tax 
jurisdiction for regulatory purposes; 
‘‘(G) total accumulated earnings, except 
that accumulated earnings of a permanent es-
tablishment must be reported by the legal entity 
of which it is a permanent establishment; 
‘‘(H) total number of employees on a full- 
time equivalent basis; and 
‘‘(I) net book value of tangible assets, 
which, for purposes of this section, does not in-
clude cash or cash equivalents, intangibles, or 
financial assets. 
‘‘(3) AVAILABILITY
OF
INFORMATION.—The 
Commission shall make the information filed with 
the Commission pursuant to this subsection publicly 
available through the Commission website in a man-
ner that is searchable, sortable, and downloadable.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to disclosures made after the date 
of the enactment of this Act. 
SEC. 107. PENALTY FOR ELECTION TO PAY TAX ON DE-
FERRED 
FOREIGN 
INCOME 
IN 
INSTALL-
MENTS. 
(a) IN GENERAL.—Section 965(h) is amended by 
adding at the end the following new paragraph: 
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‘‘(7) PENALTY.—Interest on installments under 
this subsection shall be payable as determined under 
section 6601 by treating the last date prescribed for 
payment for any installment as the date for payment 
of the first installment under this subsection.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
subsection (a) shall take effect as if included in section 
14103 of Public Law 115–97. 
TITLE 
II—ADDITIONAL 
MEAS-
URES TO COMBAT TAX EVA-
SION 
SEC. 201. AUTHORIZING SPECIAL MEASURES AGAINST FOR-
EIGN JURISDICTIONS, FINANCIAL INSTITU-
TIONS, AND OTHERS THAT SIGNIFICANTLY 
IMPEDE UNITED STATES TAX ENFORCEMENT. 
(a) IN GENERAL.—Section 5318A of title 31, United 
States Code, is amended— 
(1) by striking the section heading and insert-
ing the following: ‘‘Special measures for juris-
dictions, financial institutions, or inter-
national transactions that are of primary 
money laundering concern or signifi-
cantly impede United States tax enforce-
ment’’; 
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(2) in subsection (a), by striking the subsection 
heading and inserting the following: ‘‘SPECIAL 
MEASURES TO COUNTER MONEY LAUNDERING AND 
EFFORTS
TO
SIGNIFICANTLY
IMPEDE
UNITED 
STATES TAX ENFORCEMENT’’; 
(3) in subsection (c)— 
(A) by striking the subsection heading and 
inserting the following: ‘‘CONSULTATIONS AND 
INFORMATION TO BE CONSIDERED IN FINDING 
JURISDICTIONS, INSTITUTIONS, TYPES OF AC-
COUNTS, OR TRANSACTIONS TO BE OF PRI-
MARY MONEY LAUNDERING CONCERN OR TO 
BE SIGNIFICANTLY IMPEDING UNITED STATES 
TAX ENFORCEMENT’’; and 
(B) in paragraph (2), by adding at the end 
the following: 
‘‘(C) OTHER CONSIDERATIONS.—The fact 
that a jurisdiction or financial institution is co-
operating with the United States on imple-
menting the requirements specified in chapter 4 
of the Internal Revenue Code of 1986 may be 
favorably considered in evaluating whether such 
jurisdiction or financial institution is signifi-
cantly impeding United States tax enforce-
ment.’’; 
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(4) in subsection (a)(1), by inserting ‘‘or is sig-
nificantly impeding United States tax enforcement’’ 
after ‘‘primary money laundering concern’’; 
(5) in subsection (a)(4)— 
(A) in subparagraph (A)— 
(i) by inserting ‘‘in matters involving 
money laundering,’’ before ‘‘shall consult’’; 
and 
(ii) by striking ‘‘and’’ at the end; 
(B) by redesignating subparagraph (B) as 
subparagraph (C); and 
(C) by inserting after subparagraph (A) 
the following: 
‘‘(B) in matters involving United States 
tax enforcement, shall consult with the Commis-
sioner of Internal Revenue, the Secretary of 
State, the Attorney General of the United 
States, and in the sole discretion of the Sec-
retary, such other agencies and interested par-
ties as the Secretary may find to be appro-
priate; and’’; 
(6) in each of paragraphs (1)(A), (2), (3), and 
(4) of subsection (b), by inserting ‘‘or to be signifi-
cantly impeding United States tax enforcement’’ 
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after ‘‘primary money laundering concern’’ each 
place that term appears; 
(7) in subsection (b), by striking paragraph (5) 
and inserting the following: 
‘‘(5) PROHIBITIONS OR CONDITIONS ON OPEN-
ING OR MAINTAINING CERTAIN CORRESPONDENT OR 
PAYABLE-THROUGH
ACCOUNTS
OR
AUTHORIZING 
CERTAIN PAYMENT CARDS.—If the Secretary finds a 
jurisdiction outside of the United States, 1 or more 
financial institutions operating outside of the United 
States, or 1 or more classes of transactions within 
or involving a jurisdiction outside of the United 
States to be of primary money laundering concern or 
to be significantly impeding United States tax en-
forcement, the Secretary, in consultation with the 
Secretary of State, the Attorney General of the 
United States, and the Chairman of the Board of 
Governors of the Federal Reserve System, may pro-
hibit, or impose conditions upon— 
‘‘(A) the opening or maintaining in the 
United States of a correspondent account or 
payable-through account by any domestic finan-
cial institution or domestic financial agency for 
or on behalf of a foreign banking institution, if 
such correspondent account or payable-through 
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account involves any such jurisdiction or insti-
tution, or if any such transaction may be con-
ducted through such correspondent account or 
payable-through account; or 
‘‘(B) the authorization, approval, or use in 
the United States of a credit card, charge card, 
debit card, or similar credit or debit financial 
instrument by any domestic financial institu-
tion, domestic financial agency, or credit card 
company or association for or on behalf of a 
foreign banking institution, if such credit card, 
charge card, debit card, or similar credit or 
debit financial instrument involves any such ju-
risdiction or institution, or if any such trans-
action may be conducted through such credit 
card, charge card, debit card, or similar credit 
or debit financial instrument.’’; 
(8) in subsection (c)(1), by inserting ‘‘or is sig-
nificantly impeding United States tax enforcement’’ 
after ‘‘primary money laundering concern’’; 
(9) in subsection (c)(2)(A)— 
(A) in clause (ii), by striking ‘‘bank secrecy 
or special regulatory advantages’’ and inserting 
‘‘bank, tax, corporate, trust, or financial secrecy 
or regulatory advantages’’; 
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(B) in clause (iii), by striking ‘‘supervisory 
and counter-money’’ and inserting ‘‘supervisory, 
international tax enforcement, and counter- 
money’’; 
(C) in clause (v), by striking ‘‘banking or 
secrecy’’ and inserting ‘‘banking, tax, or se-
crecy’’; and 
(D) in clause (vi), by inserting ‘‘, tax trea-
ty, or tax information exchange agreement’’ 
after ‘‘treaty’’; 
(10) in subsection (c)(2)(B)— 
(A) in clause (i), by inserting ‘‘or tax eva-
sion’’ after ‘‘money laundering’’; and 
(B) in clause (iii), by inserting ‘‘, tax eva-
sion,’’ after ‘‘money laundering’’; and 
(11) in subsection (d), by inserting ‘‘involving 
money laundering, and shall notify, in writing, the 
Committee on Finance of the Senate and the Com-
mittee on Ways and Means of the House of Rep-
resentatives of any such action involving United 
States tax enforcement’’ after ‘‘such action’’. 
(b) CLERICAL AMENDMENT.—The table of contents 
for chapter 53 of title 31, United States Code, is amended 
by striking the item relating to section 5318A and insert-
ing the following: 
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