I 
117TH CONGRESS 
1ST SESSION H. R. 1786 
To end offshore corporate tax avoidance, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
MARCH 11, 2021 
Mr. DOGGETT (for himself, Mr. BLUMENAUER, Mr. COHEN, Mr. DANNY K. 
DAVIS of Illinois, Mr. DEFAZIO, Ms. DELAURO, Mr. GARAMENDI, Mr. 
GRIJALVA, Ms. JAYAPAL, Ms. JOHNSON of Texas, Mr. JOHNSON of Geor-
gia, Mr. MFUME, Mr. NADLER, Mr. RASKIN, Mr. SARBANES, Ms. SCHA-
KOWSKY, Mr. TONKO, Ms. WATERS, Mrs. WATSON COLEMAN, and Mr. 
CARTWRIGHT) introduced the following bill; which was referred to the 
Committee on Ways and Means, and in addition to the Committee on Fi-
nancial Services, for a period to be subsequently determined by the 
Speaker, in each case for consideration of such provisions as fall within 
the jurisdiction of the committee concerned 
A BILL 
To end offshore corporate tax avoidance, and for other 
purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE, ETC. 
(a) SHORT TITLE.—This Act may be cited as the 
‘‘Stop Tax Haven Abuse Act’’. 
(b) AMENDMENT OF 1986 CODE.—Except as other-
wise expressly provided, whenever in this Act an amend-
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ment or repeal is expressed in terms of an amendment 
to, or repeal of, a section or other provision, the reference 
shall be considered to be made to a section or other provi-
sion of the Internal Revenue Code of 1986. 
(c) TABLE OF CONTENTS.—The table of contents of 
this Act is as follows: 
Sec. 1. Short title, etc. 
TITLE I—ENDING CORPORATE OFFSHORE TAX AVOIDANCE 
Sec. 101. Repeal of check-the-box rules for certain foreign entities and CFC 
look-thru rules. 
Sec. 102. Swap payments made from the United States to persons offshore. 
Sec. 103. Requirement to disclose total corporate taxes paid. 
Sec. 104. Penalty for election to pay tax on deferred foreign income in install-
ments. 
Sec. 105. Modifications to base erosion and anti-abuse tax. 
Sec. 106. Treatment of foreign base company oil related income as subpart F 
income. 
Sec. 107. Modifications of foreign tax credit rules applicable to dual capacity 
taxpayers. 
Sec. 108. Treatment of intangibles transferred to partnerships. 
TITLE II—ADDITIONAL MEASURES TO COMBAT TAX EVASION 
Sec. 201. Authorizing special measures against foreign jurisdictions, financial 
institutions, and others that significantly impede United States 
tax enforcement. 
Sec. 202. Strengthening the Foreign Account Tax Compliance Act (FATCA). 
Sec. 203. Reporting United States beneficial owners of foreign owned financial 
accounts. 
Sec. 204. Penalty for failing to disclose offshore holdings. 
Sec. 205. Deadline for anti-money laundering rule for investment advisers. 
Sec. 206. Anti-money laundering requirements for formation agents. 
Sec. 207. Strengthening John Doe summons proceedings. 
Sec. 208. Improving enforcement of foreign financial account reporting. 
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TITLE I—ENDING CORPORATE 
OFFSHORE TAX AVOIDANCE 
SEC. 101. REPEAL OF CHECK-THE-BOX RULES FOR CERTAIN 
FOREIGN ENTITIES AND CFC LOOK-THRU 
RULES. 
(a) CHECK-THE-BOX RULES.—Paragraph (3) of sec-
tion 7701(a) is amended— 
(1) by striking ‘‘and’’, and 
(2) by inserting after ‘‘insurance companies’’ 
the following: ‘‘, and any foreign business entity 
that— 
‘‘(A) has a single owner that does not have 
limited liability, or 
‘‘(B) has one or more members all of 
which have limited liability’’. 
(b) LOOK-THRU RULE.—Subparagraph (C) of sec-
tion 954(c)(6) is amended to read as follows: 
‘‘(C) TERMINATION.—Subparagraph (A) 
shall not apply to dividends, interest, rents, and 
royalties received or accrued after the date of 
the enactment of the Stop Tax Haven Abuse 
Act.’’. 
(c) EFFECTIVE DATE.— 
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a swap payment is determined by reference to the lo-
cation of the payor.’’. 
SEC. 103. 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. 104. 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. 
SEC. 105. MODIFICATIONS TO BASE EROSION AND ANTI- 
ABUSE TAX. 
(a) REDUCTION OF EXEMPTION BASED ON ANNUAL 
GROSS RECEIPTS.—Section 59A(e)(1)(B) is amended by 
striking ‘‘$500,000,000’’ and inserting ‘‘$100,000,000’’. 
(b) ELIMINATION OF EXCEPTION BASED ON BASE 
EROSION PERCENTAGE.—Section 59(e)(1) is amended by 
inserting ‘‘and’’ at the end of subparagraph (A), by strik-
ing ‘‘, and’’ at the end of subparagraph (B) and inserting 
a period, and by striking subparagraph (C). 
(c) CERTAIN CAPITALIZED AMOUNTS INCLUDED AS 
BASE EROSION PAYMENTS.—Section 59A(d) is amended 
by redesignating paragraphs (4) and (5) as paragraphs 
(5) and (6), respectively, and by inserting after paragraph 
(3) the following new paragraph: 
‘‘(4) CERTAIN
CAPITALIZED
AMOUNTS.—Such 
term shall also include any interest, royalty, or any 
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other amount identified by the Secretary that is paid 
or accrued by the taxpayer to a foreign person which 
is a related party of the taxpayer and with respect 
to which the taxpayer increases the value of property 
under section 1016 or any other provision of this 
title.’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
SEC. 106. TREATMENT OF FOREIGN BASE COMPANY OIL RE-
LATED INCOME AS SUBPART F INCOME. 
(a) IN GENERAL.—Section 954(a) is amended by 
striking ‘‘and’’ at the end of paragraph (2), by striking 
the period at the end of paragraph (3) and inserting ‘‘, 
and’’, and by adding at the end the following new para-
graph: 
‘‘(4) the foreign base company oil related in-
come for the taxable year (determined under sub-
section (g) and reduced as provided in subsection 
(b)(5)).’’. 
(b) FOREIGN BASE COMPANY OIL RELATED IN-
COME.—Section 954 is amended by inserting after sub-
section (e) the following new subsection: 
‘‘(g) FOREIGN BASE COMPANY OIL RELATED IN-
COME.—For purposes of this section, the term ‘foreign 
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base company oil related income’ means foreign oil related 
income (within the meaning of paragraphs (2) and (3) of 
section 907(c)) other than income derived from a source 
within a foreign country in connection with— 
‘‘(1) oil or gas which was extracted from an oil 
or gas well located in such foreign country, or 
‘‘(2) oil, gas, or a primary product of oil or gas 
which is sold by the foreign corporation or a related 
person for use or consumption within such country 
or is loaded in such country on a vessel or aircraft 
as fuel for such vessel or aircraft. 
Such term shall not include any foreign personal holding 
company income (as defined in subsection (c)).’’. 
(c) CONFORMING AMENDMENTS.— 
(1) Section 952(c)(1)(B)(iii) is amended by re-
designating subclauses (III) and (IV) as subclauses 
(IV) and (V), respectively, and by inserting after 
subclause (II) the following new subclause: 
‘‘(III) foreign base company oil 
related income.’’. 
(2) Section 954(b) is amended— 
(A) by striking ‘‘and the foreign base com-
pany services income’’ in paragraph (5) and in-
serting ‘‘the foreign base company services in-
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