Stop Corporate Inversions Act of 2026

Expanded Tax Treatment for Domestic Corporations: Under Section 2(a)(1)(A), a foreign corporation may be treated as a domestic corporation if it would be a surrogate foreign corporation when substituting '80 percent' for '60 percent'.

Clearer Standards for Management and Control: Section 2(a)(4)(B) provides a specific standard where management and control is treated as occurring primarily in the United States if substantially all executive officers and senior management responsible for strategic, financial, and operational policies are based in the United States.

Defined Domestic Business Activity: Section 2(a)(5) establishes that an expanded affiliated group has significant domestic business activities if at least 25 percent of its employees, employee compensation, assets, or income meet specific criteria within the United States.

Increased Tax Status for Foreign Entities: According to Section 2(a)(1), certain foreign corporations will now be treated as domestic corporations for the purposes of the Internal Revenue Code.

New Definitions for Inverted Domestic Corporations: Section 2(a)(2) creates a scenario where a foreign corporation is treated as an inverted domestic corporation if it acquires substantially all properties or assets of a domestic corporation or partnership and meets specific stock ownership or management control thresholds.

Potential Burden of Regulation: Section 2(a)(4)(A) states that the Secretary shall prescribe regulations for determining if the management and control of an expanded affiliated group occurs primarily within the United States.