{"@context":"https://schema.org","@type":"Legislation","name":"To eliminate the incentive for corporations to continue to hold accumulated earnings offshore, to invest in domestic infrastructure, to provide for international tax reform, and for other purposes.","description":"

Infrastructure 2.0 Act

This bill amends the Internal Revenue Code, with respect to the taxation of earnings and profits of a deferred foreign income corporation, to: (1) make such earnings and profits subject to taxation in the last year that ends before the enactment of this bill; (2) reduce the tax rate on such earnings and profits by allowing an exemption of 75% (equal to a tax of 8.75% of repatriated earnings and profits); and (3) allow corporations to pay the tax in installments.

The bill also:

establishes and provides appropriations for a fund to assist various public and private entities in investing in public infrastructure projects,
appropriates revenues from this bill to the Highway Trust Fund (HTF),
establishes a commission to make recommendations to achieve long-term solvency of the HTF and requires Congress to consider the proposed legislation using expedited procedures, and
directs the Department of Transportation to establish a regional infrastructure accelerator pilot program to assist public entities in developing infrastructure projects.

The bill establishes a deadline of 18 months after the enactment of this bill for the enactment of legislation to reform the international tax system by eliminating the incentive to hold earnings in low-tax foreign jurisdictions. If the legislation is not enacted by the deadline, a specified reform proposal takes effect, which includes provisions relating to subpart F income and insurance income, the taxation of repatriated offshore corporate earnings, gains and losses from the sale or exchange of stock in controlled foreign corporations, limitations on the foreign tax credit, and the tax treatment of previously deferred foreign income.

","legislationIdentifier":"HR 1670","legislationType":"Bill","legislationLegalForce":"NotInForce","legislationJurisdiction":"USA","author":[{"@type":"Person","name":"John K. Delaney","url":"https://legisdaily.com/mp/johnk-delaney-us"}],"about":{"@type":"Thing","name":"Taxation"},"keywords":"Accounting and auditing, Administrative law and regulatory procedures, Advisory bodies, Business expenses, Capital gains tax, Congressional operations and organization, Congressional oversight, Corporate finance and management, Department of the Treasury, Executive agency funding and structure, Financial services and investments, Foreign and international corporations, Government corporations and government-sponsored enterprises, Government trust funds, Income tax credits, Income tax deductions, Income tax rates, Infrastructure development, Insurance industry and regulation, Interest, dividends, interest rates, Internal Revenue Service (IRS), Legislative rules and procedure, Roads and highways, Securities, Tax administration and collection, taxpayers, Taxation of foreign income, Transportation programs funding","dateModified":"2025-04-07T00:00:00.000Z","url":"https://legisdaily.com/bill/USA-115-HR-1670"}