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.

The bill would amend the Internal Revenue Code to exclude certain payments made to foreign related parties from being treated as base erosion payments if the foreign recipient is subject to an effective foreign income tax rate of at least 15 percent. It would allow taxpayers to demonstrate this tax rate using applicable financial statements with specified adjustments, and define foreign income taxes broadly to include income, war profits, or excess profits taxes paid to foreign countries or U.S. possessions. The changes would apply to taxable years beginning after the date of enactment and include provisions for regulatory guidance to prevent abuse or avoidance.

No official summary is available here. This one was written by AI from the bill’s text.