{"@context":"https://schema.org","@type":"Legislation","name":"To amend the Internal Revenue Code of 1986 to limit the interest deduction for excessive interest of members of financial reporting groups and to terminate the deferral of active income of controlled foreign corporations, and to amend the Securities Exchange Act of 1934 to require the disclosure of total corporate tax paid by a corporation in each annual report required to be filed under such Act, and for other purposes.","description":"

Tax Fairness and Transparency Act

This bill amends the Internal Revenue Code to limit the tax deduction of the interest expense of a U.S. corporation that is a member of a financial reporting group (a group that prepares consolidated financial statements according to accepted accounting principles or international financial reporting standards) to: (1) the amount of interest on indebtedness of the corporation includible in the corporation's gross income for the taxable year plus its proportionate share of the group's net interest expense in the taxable year computed under U.S. income tax principles; or (2) not more than 10% of the corporation's adjusted taxable income, if the corporation fails to substantiate its proportionate share of interest expense or so elects.

The bill exempts from the limitation a corporation that is predominantly engaged in the active conduct of a banking, financing, or similar business or that has less than $5 million of net interest expense for the taxable year.

The bill also modifies the definition of subpart F income (i.e., income of a controlled foreign corporation earned outside the United States that is not tax-deferred) to include income of a controlled foreign corporation derived from any foreign country. This modification is applicable to taxable years beginning after December 31, 2017.

The bill amends the Securities Exchange Act of 1934 to require each issuer of a security who is required to file an annual or quarterly report to disclose specified: (1) details regarding pre-tax profits and taxes paid; and (2) corporate financial information, aggregated on a country-by-country basis, for each of its subsidiaries.

","legislationIdentifier":"HR 2057","legislationType":"Bill","legislationLegalForce":"NotInForce","legislationJurisdiction":"USA","author":[{"@type":"Person","name":"Mark Pocan","url":"https://legisdaily.com/mp/mark-pocan-us"}],"about":{"@type":"Thing","name":"Taxation"},"keywords":"Accounting and auditing, Business records, Corporate finance and management, Financial services and investments, Foreign and international corporations, Government information and archives, Income tax deductions, Interest, dividends, interest rates, Securities, State and local taxation, Taxation of foreign income","dateModified":"2025-01-03T00:00:00.000Z","url":"https://legisdaily.com/bill/USA-115-HR-2057"}

Mark Pocan

Mark Pocan

Ways and Means Committee, Financial Services Committee