S. 409119th CongressIn committeeLatest action Feb 5, 2025Decoded by AI · checked against the record
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Senate bill S 409 would close offshore tax loopholes for large US multinationals, targeting foreign subsidiaries, inversions, and debt-shifting.
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S 409 would require US companies to pay taxes on foreign subsidiary profits annually on a country-by-country basis rather than using a blended global rate. It removes a reduced tax rate on certain foreign earnings and eliminates a deduction that lets companies load US operations with debt to shift profits abroad. It also tightens rules on corporate inversions and would treat foreign companies managed from within the US as American companies for tax purposes.
The bill primarily affects large multinational corporations with significant overseas operations or foreign subsidiaries. Foreign companies that do substantial business in the US but are managed from American soil would also be affected.
Applying taxes country by country would prevent companies from using blended global rates to obscure low-tax arrangements. Tightening inversion rules and the management-location test would limit companies from reducing their US tax bill through corporate structure changes.
AI-drafted summary. Verify it against the official text before you act on it. Read the official bill on Congress.gov
Right now: a Senate committee is reviewing it. If the House changes it, it goes back to the Senate before reaching the President.
Latest action: — Read twice and referred to the Committee on Finance.