Draft Bill Introduced in U.S. House of Representatives to Amend CFC/GILTI Rules

U.S. Representative Peter DeFazio (D-OR) has announced the introduction of the Per-Country Minimum Act (Bill H.R. 6015), which would amend the Internal Revenue Code to increase the tax on certain global intangible income. The measures of the Bill would provide for:

• A reduction in the deduction for global intangible low-taxed income from 50% to 37.5% for taxable years before 2026 and reduce the deduction from 37.5% to 21.875% for taxable years after 2025;
• The repeal of tax-free deemed return…