U.S. Innovation and Global Competitiveness Act of 2026
Rep. Ron Estes (R-KS) introduced this bill to modify multiple tax provisions affecting U.S. corporations with foreign operations and income. The bill changes how foreign-derived intangible income is deducted, alters base erosion minimum tax rules, modifies foreign tax credit baskets and carryover rules, and repeals several tax provisions including the foreign tax credit haircut and inclusion percentages for deemed paid credits. It also eliminates taxation of foreign base company sales income under certain conditions, exempts some corporations from subpart F inclusion for certain investments, and creates special rules for transfers of intangible property from U.S. to foreign entities. The bill was referred to the House Committee on Ways and Means on September 16, 2026.
What’s in the bill (11 sections)
- Sec. 2. Modification of deduction for foreign-derived intangible income
- Sec. 3. Modifications to base erosion minimum tax
- Sec. 4. Modification of foreign tax credit limitation baskets
- Sec. 5. Carryover of net CFC tested loss
- Sec. 6. Redetermination of foreign taxes and related claims
- Sec. 7. Repeal of foreign tax credit haircut for net controlled foreign
- Sec. 8. Repeal of inclusion percentage applicable to deemed paid credit
- Sec. 9. Application of foreign-source dividend deduction to amounts
- Sec. 10. Elimination of inclusion of foreign base company sales income
- Sec. 11. Corporations exempt from subpart F inclusion for investment in
- Sec. 12. Special rules for transfers of intangible property from
Where it is in the process
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