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S. 922 (114th): Corporate Tax Dodging Prevention Act

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The summary below was written by the Congressional Research Service, which is a nonpartisan division of the Library of Congress, and was published on Apr 14, 2015.


Corporate Tax Dodging Prevention Act

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, 2015; 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).