Corporate Tax Dodging Prevention Act

Corporate Tax Dodging Prevention Act

This bill modifies tax provisions relating to certain large domestic and foreign corporations to prevent offshoring of jobs and factories and tax evasion.

Specifically, the bill

• restores higher tax rates on the taxable income of corporations and personal service corporations (up to 35% on taxable income exceeding $10 million);
• revises the definition of subpart F income for controlled foreign corporations to equalize tax rates on domestic and foreign corporations;
• requires multinational companies to disclose basic country-by-country information including revenues, profits, and number of employees;
• prohibits corporations from disregarding parts of their structure in determining whether they owe taxes in the current year or can defer payment (repeal of check-the-box rules);
• impose limitations on the tax deduction for the interest expense of members of financial reporting groups with excess domestic indebtedness;
• modifies rules relating to inverted corporations;
• treats corporations with gross assets of $50 million or more and managed and controlled in the United States as U.S. taxpayers;
• increases the rate and expands the applicability of the base erosion and anti-abuse excise tax;
• modifies foreign tax credit rules applicable to certain industries receiving specific economic benefits; and
• repeals the tax deduction for foreign-derived intangible income.