HR 1911
To amend the Internal Revenue Code of 1986 to provide that certain payments to foreign related parties subject to sufficient foreign tax are not treated as base erosion payments.
Jurisdiction
US Congress
Session
119th Congress (2025-2026)
Last updated at
Jun 14, 2026, 6:45 AM
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Sign in to take action- Introduced
- Passed House
- Passed Senate
- To President
- Became Law
Bill overview
This bill aims to clarify how the IRS treats payments made to foreign-related parties. Specifically, it proposes to exclude certain payments that are subject to a sufficient foreign tax rate (at least 15%) from being classified as ‘base erosion payments.’ This means that if a company pays a foreign entity and that entity pays taxes at a rate of 15% or higher, the payment won't be considered a way to reduce the company's tax base in the United States. The bill also includes provisions for determining the foreign tax rate and preventing potential tax avoidance strategies.
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