Bills · HR 1911
IN COMMITTEE· 119TH CONGRESS
House BillHR 1911Taxation
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.
INTRO MAR 6· LAST ACTION MAR 6
READING
3MIN
COSPONSORS
2BIPARTISAN
READER REACTIONS0 TOTAL
NO VOTES YET · BE THE FIRST
- Introduced only
LEGISLATIVE PROGRESS
STEP 2 / 8Introduced
In Committee
Reported
Passed House
Passed Senate
Conference
To President
Became Law
WHAT THE BILL DOES
AI-writtenThis bill matters because it directly impacts the tax burden on large multinational U.S. corporations, particularly those with complex international structures. The Base Erosion and Anti-abuse Tax (BEAT) was designed to ensure that even companies sending profits abroad still pay a minimum U.S. tax. By creating an exception for payments already taxed at 15% or more overseas, this bill could reduce the tax liability for some U.S. companies, making it potentially more attractive to operate through foreign subsidiaries in countries with moderately high tax rates.
If this bill becomes law, U.S. companies might find it easier and less costly to structure international operations, as they would avoid an additional U.S. tax on certain payments already subject to a significant foreign tax. This could be seen as reducing double taxation and improving U.S. competitiveness in a global economy. If it doesn't become law, the BEAT rules would continue to apply broadly to "base erosion payments," potentially leading to higher tax bills for some companies or encouraging them to move operations to countries with very low tax rates to avoid the 15% threshold for this specific exclusion.
KEY PROVISIONS
3AI-extractedPROVISION 01
Payments made by a U.S. company to a foreign related company will not be counted as "base erosion payments" if that foreign company, or the payment itself, is subject to at least a 15% effective foreign income tax rate.
This creates an important exception to the Base Erosion and Anti-abuse Tax (BEAT), potentially reducing tax burdens for some multinational companies.
PROVISION 02
The effective foreign tax rate can be determined using a foreign company's financial statements, with specific adjustments provided by the U.S. Treasury.
This outlines how companies can prove they meet the 15% tax threshold, providing clarity for compliance.
PROVISION 03
The Treasury Secretary is authorized to create further rules for determining the effective foreign tax rate and to prevent tax avoidance or abuse of this new exception.
This gives the government power to ensure the new rule is applied fairly and doesn't create new loopholes.
SPONSORSHIP
1 + 2
D· New Jersey
YRS IN OFFICE
1
BILLS LED
15
COSPONSOR BREAKDOWNBIPARTISAN · 100%
DEM 1 REP 1 IND 0
ACTION TIMELINE
2 EVENTSMAR 6
Introduced in House
MAR 6
Referred to the House Committee on Ways and Means.
BILL INFO
TypeHouse Bill
NumberHR 1911
Congress119th
StatusIn Committee
IntroducedMar 6, 2025
Last actionMar 6, 2025
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IN COMMITTEE· 119TH CONGRESS · WAYS AND MEANS COMMITTEE · INTRODUCED MAR 6, 2025
House BillHR 1911Taxation
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.
INTRODUCED MAR 6, 2025· LAST ACTION MAR 6, 2025
PASSAGE CHANCES
—%
READING
3 min
COSPONSORS
2
COMPLEXITY
Moderate
