A Republican bill with no cosponsors
Last activity — Read twice and referred to the Committee on Finance.
In committee
Introduced and handed to a committee in the chamber it started in.
The committee holds it, and most bills are never heard from again. A hearing or a committee vote would be news; silence is the usual outcome, and it kills the bill without anyone voting against it.
Its path through Congress
- Introduced
- In Committee
What this bill would do
The International Competition for American Jobs Act modifies how international entities are taxed under the Internal Revenue Code of 1986. It permanently extends the look-through rule for controlled foreign corporations and adjusts deductions for foreign-derived and global intangible low-taxed income. The bill also changes the base erosion minimum tax and modifies foreign tax credit limitations. Additionally, it repeals certain foreign base company income inclusions and creates special rules for transferring intangible property to U.S. shareholders. Finally, it provides specific exemptions for certain services income derived from the Virgin Islands.
Yes· 3 of 12
- Scored +6
Would business owners be better off under this?
Significantly reduces tax burdens for business owners with international operations through deductions and rule extensions.
- Scored +6
Would billionaires be better off under this?
Directly modifies the taxation of large-scale global intangible income and foreign controlled corporations.
- Scored +5
Would the very wealthiest people be better off under this?
Targeted at complex international tax structures primarily utilized by the ultra-wealthy.
The opposite
- Scored -3
Does this raise the taxes companies pay?
While it provides deductions, it introduces new tax inclusions for foreign-controlled US shareholders.
- Scored -2
Does this raise taxes on the highest earners?
Introduces new gross income inclusions for specific high-net-worth shareholders of foreign corporations.
Who it would affect, and how
Potential Positive Impacts for People
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Permanent Extension of Look-Thru Rule: Section 2 permanently extends the look-through rule for controlled foreign corporations, removing the previous January 1, 2026, expiration date.
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Increased Tax Deductions: Section 3 modifies deductions for domestic corporations, allowing 37.5 percent of foreign-derived deduction eligible income and 50 percent of global intangible low-taxed income.
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Base Erosion Tax Exceptions: Section 4(d) creates exceptions for base erosion payments if the amount is already taxed by the chapter or if the foreign person is subject to an effective foreign income tax rate of at least 18.9 percent.
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CFC Tested Loss Carryover: Section 7 allows United States shareholders to carry over net CFC tested losses to succeeding taxable years.
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Foreign Tax Credit Improvement: Section 9 repeals the "80 percent of" haircut for global intangible low-taxed income, which may increase available credits.
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Intangible Property Transfer Benefits: Section 14 allows for the distribution of certain intangible property from a controlled foreign corporation to a domestic corporation where the fair market value is treated as not exceeding the adjusted basis.
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Virgin Islands Services Exemption: Section 15 excludes qualified Virgin Islands services income from global intangible low-taxed income for specified United States shareholders.
Potential Negative Impacts for People
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New Tax Inclusions for Foreign Controlled Shareholders: Section 6(b) introduces Section 951B, which requires foreign controlled United States shareholders to include certain amounts in their gross income.
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New Compliance and Regulations: Section 4(d)(2)(D) and Section 6(d) give the Secretary of the Treasury authority to issue new regulations and guidance to prevent avoidance, which may increase the regulatory burden on taxpayers.
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Modified Credit Limitations: Section 5 modifies foreign tax credit limitation baskets and changes how certain deductions are allocated to foreign source global intangible low-taxed income.
Groups and Interests Ranking
Every group the model scored this bill for, from -10 to +10. Tap or hover a score for the reason it gave.
- Demographic And Interest Groups
- Would billionaires be better off under this? — Directly modifies the taxation of large-scale global intangible income and foreign controlled corporations. Would business owners be better off under this? — Significantly reduces tax burdens for business owners with international operations through deductions and rule extensions. Would the very wealthiest people be better off under this? — Targeted at complex international tax structures primarily utilized by the ultra-wealthy. Would people with substantial wealth be better off under this? — Offers specific tax advantages and intangible property transfer rules beneficial to wealthy investors. Would high-income households be better off under this? — Benefits wealthy individuals who are shareholders of foreign controlled corporations via tax modifications.
- Economy And Finance
- Is this likely to grow the economy? — Increases the competitiveness of US corporations by reducing tax frictions on international operations and intangible property. Does this make it easier to run a small business? — Benefits small business owners operating through closely held C corporations via specific exclusions and deductions. Does this cut taxes for small businesses? — Provides benefits for closely held C corporations and modifies deductions for foreign-derived income. Is this likely to create jobs? — Aims to make the US more competitive for jobs by modifying international tax burdens on domestic corporations. Does this raise the taxes companies pay? — While it provides deductions, it introduces new tax inclusions for foreign-controlled US shareholders. Does this raise taxes on the highest earners? — Introduces new gross income inclusions for specific high-net-worth shareholders of foreign corporations.
- Education And Technology
- Does this make patent and copyright rules fairer? — Provides favorable tax treatment for transferring intangible property from foreign subsidiaries to US shareholders.
- National Security And Foreign Policy
- Does this make trade with other countries easier? — Reduces tax penalties for US companies operating internationally, potentially facilitating smoother trade.
- Governance And Ideology
- Does this give the federal government more power? — Grants the Secretary of the Treasury expanded authority to issue regulations to prevent tax avoidance.
- 5/6/2025
- Read twice and referred to the Committee on Finance.
- Introduced in Senate
2 bills Congress.gov lists as related to this one — companions in the other chamber, earlier versions, and bills this one absorbed or was folded into.