SEC. 70341. Coordination of business interest limitation with interest capitalization provisions. (a) In general.—Section 163(j) is amended by redesignating paragraphs (10) and (11) as paragraphs (11) and (12) and by inserting after paragraph (9) the following: “(10) COORDINATION WITH INTEREST CAPITALIZATION PROVISIONS.— “(A) IN GENERAL.—In applying this
SEC. 70342. Definition of adjusted taxable income for business interest limitation. (a) In general.—Subparagraph (A) of section 163(j)(8) is amended— (1) by striking “and” at the end of clause (iv), and (2) by adding at the end the following new clause: “(vi) the amounts included in gross
(a) In general.—Section 163(j) is amended by redesignating paragraphs (10) and (11) as paragraphs (11) and (12) and by inserting after paragraph (9) the following: “(10) COORDINATION WITH INTEREST CAPITALIZATION PROVISIONS.— “(A) IN GENERAL.—In applying this subsection— “(i) the limitation under paragraph (1) shall apply to business
SEC. 70331. Extension and modification of base erosion minimum tax amount. (a) In general.—Section 59A(b) is amended— (1) by striking “10 percent” in paragraph (1) and inserting “10.5 percent”, and (2) by striking paragraph (2) and by redesignating paragraphs (3) and (4) as paragraphs (2) and (3)
(a) In general.—Section 59A(b) is amended— (1) by striking “10 percent” in paragraph (1) and inserting “10.5 percent”, and (2) by striking paragraph (2) and by redesignating paragraphs (3) and (4) as paragraphs (2) and (3), respectively. (b) Conforming amendments.— (1) Section 59A(b)(1) is amended
SEC. 70321. Modification of deduction for foreign-derived deduction eligible income and net CFC tested income. (a) In general.—Section 250(a) is amended— (1) by striking “37.5 percent” in paragraph (1)(A) and inserting “33.34 percent”, (2) by striking “50 percent” in paragraph (1)(B) and inserting
(a) Taxation of net CFC tested income.— (1) IN GENERAL.—Section 951A(a) is amended by striking “global intangible low-taxed income” and inserting “net CFC tested income”. (2) REPEAL OF TAX-FREE DEEMED RETURN ON FOREIGN INVESTMENTS.—Section 951A, as amended by the preceding provisions of this Act, is
(a) Sales or other dispositions of certain property.— (1) IN GENERAL.—Section 250(b)(3)(A)(i) is amended— (A) by striking “and” at the end of subclause (V), (B) by striking “over” at the end of subclause (VI) and inserting “and”, and (C) by adding at the end the
(a) In general.—Section 250(a) is amended— (1) by striking “37.5 percent” in paragraph (1)(A) and inserting “33.34 percent”, (2) by striking “50 percent” in paragraph (1)(B) and inserting “40 percent”, and (3) by striking paragraph (3). (b) Effective date.—The amendments made by this
SEC. 70311. Modifications related to foreign tax credit limitation. (a) Rules for allocation of certain deductions to foreign source net CFC tested income for purposes of foreign tax credit limitation.—Section 904(b) is amended by adding at the end the following new paragraph: “(5) DEDUCTIONS TREATED AS ALLOCABLE TO
(a) In general.—Section 904(b), as amended by section 70311, is amended by adding at the end the following new paragraph: “(6) SOURCE RULES FOR CERTAIN INVENTORY PRODUCED IN THE UNITED STATES AND SOLD THROUGH FOREIGN BRANCHES.—For purposes of this section, if a United States person maintains an
(a) Increase in deemed paid credit.— (1) IN GENERAL.—Section 960(d)(1) is amended by striking “80 percent” and inserting “90 percent”. (2) GROSS UP FOR DEEMED PAID FOREIGN TAX CREDIT.—Section 78 is amended— (A) by striking “subsections (a), (b), and (d)” and inserting “subsections (a) and (d)