[Congressional Bills 116th Congress]
[From the U.S. Government Publishing Office]
[S. 3280 Introduced in Senate (IS)]

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116th CONGRESS
  2d Session
                                S. 3280

 To amend the Internal Revenue Code of 1986 to clarify that high-taxed 
  amounts are excluded from tested income for purposes of determining 
   global intangible low-taxed income only if such amounts would be 
            foreign base company income or insurance income.


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                   IN THE SENATE OF THE UNITED STATES

                           February 12, 2020

 Mr. Wyden (for himself and Mr. Brown) introduced the following bill; 
     which was read twice and referred to the Committee on Finance

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                                 A BILL


 
 To amend the Internal Revenue Code of 1986 to clarify that high-taxed 
  amounts are excluded from tested income for purposes of determining 
   global intangible low-taxed income only if such amounts would be 
            foreign base company income or insurance income.

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

SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Blocking New Corporate Tax Giveaways 
Act''.

SEC. 2. CLARIFICATION OF AMOUNTS EXCLUDED FROM TESTED INCOME.

    (a) In General.--Section 951A(c)(2)(A)(i)(III) of the Internal 
Revenue Code of 1986 is amended to read as follows:
                                    ``(III) any gross income of such 
                                corporation--
                                            ``(aa) which, without 
                                        regard to section 954(b)(4), is 
                                        treated as foreign base company 
                                        income (as defined in section 
                                        954) or insurance income (as 
                                        defined in section 953), but
                                            ``(bb) which, after the 
                                        application of section 
                                        954(b)(4), is not so 
                                        treated,''.
    (b) Effective Date.--The amendment made by this section shall apply 
to taxable years of foreign corporations beginning on or after the date 
of the enactment of this Act, and to taxable years of United States 
shareholders in which or with which such taxable years of foreign 
corporations end.
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