Close the Round-Tripping Loophole Act

The Close the Round-Tripping Loophole Act amends the Internal Revenue Code to prevent U.S. corporations from reducing their global intangible low-taxed income (GILTI) tax liability through round-tripping—where income is shifted offshore and then returned to the U.S. to exploit tax benefits. It modifies the calculation of net deemed intangible income return and limits deductions for GILTI by introducing a “round-tripping ratio” that reduces allowable deductions based on the proportion of income deemed to be round-tripped, with an exception for small taxpayers having average annual gross receipts of $100 million or less. The changes apply to taxable years of foreign corporations beginning…

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