Bill · S. 1605· Senate(119-S-1605)
International Competition for American Jobs Act
- Introduced
- 5/6/2025
- Last activity
- 5/6/2025 — Read twice and referred to the Committee on Finance.
- Sponsored by
- Thomas Tillis
- Cosponsors
- None
- 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
Would business owners be better off under this?+6
Significantly reduces tax burdens for business owners with international operations through deductions and rule extensions.
Would billionaires be better off under this?+6
Directly modifies the taxation of large-scale global intangible income and foreign controlled corporations.
Would the very wealthiest people be better off under this?+5
Targeted at complex international tax structures primarily utilized by the ultra-wealthy.
The opposite
Does this raise the taxes companies pay?-3
While it provides deductions, it introduces new tax inclusions for foreign-controlled US shareholders.
Does this raise taxes on the highest earners?-2
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. Hover a score for the reason it gave.
- Demographic And Interest Groups
- Good For Billionaires+6Good For Business Owners+6Good For Ultra High Net Worth Individuals+5Good For High Net Worth Individuals+4Good For High Income Households+3
- Economy And Finance
- Improves Economic Growth+4Improves Small Business Support+3Reduces Small Business Taxes+3Increases Job Creation+2Increases Corporate Taxes-3Increases Wealthy Taxes-2
- Education And Technology
- Improves Intellectual Property Fairness+4
- National Security And Foreign Policy
- Improves International Trade+3
- Governance And Ideology
- Increases Federal Power+1
- 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.