Summary: S.586 — 115th Congress (2017-2018)All Information (Except Text)

There is one summary for S.586. Bill summaries are authored by CRS.

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Introduced in Senate (03/09/2017)

Corporate Tax Dodging Prevention Act

This bill amends the Internal Revenue Code, with respect to the taxation of the foreign-source income of domestic corporations, to:

  • eliminate the deferral of tax on the foreign-source income of U.S. corporations for taxable years beginning after December 31, 2017;
  • include previously deferred foreign-source income of corporations as taxable income;
  • deny the foreign tax credit to large integrated oil companies that are dual capacity taxpayers;
  • limit the offset of the foreign tax credit to income that is subject to U.S. tax;
  • treat foreign corporations managed and controlled in the United States as domestic corporations for U.S. tax purposes;
  • limit the tax deduction of the interest expense of a U.S. corporation that is a member of a financial reporting group (i.e., a group that prepares consolidated financial statements according to generally accepted accounting principles or international financial reporting standards); and
  • revise rules for the taxation of inverted corporations (i.e., U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States) to provide that a foreign corporation that acquires the properties of a U.S. corporation or partnership after May 8, 2014, shall be treated as an inverted corporation and thus subject to U.S. taxation if, after such acquisition it holds more than 50% of the stock of the new entity (expanded affiliated group).