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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.
3/24/2025, 1:18 PM
Summary of Bill HR 1911
Bill 119 HR 1911, also known as the "Foreign Tax Credit Protection Act," aims to amend the Internal Revenue Code of 1986 in order to clarify that certain payments made to foreign related parties, which are subject to sufficient foreign tax, should not be considered as base erosion payments.
The bill seeks to address concerns regarding the treatment of payments made to foreign related parties for tax purposes. Specifically, it aims to ensure that payments made to foreign related parties that are subject to an adequate amount of foreign tax are not unfairly penalized or categorized as base erosion payments.
By making this amendment to the Internal Revenue Code, the bill aims to provide clarity and certainty for taxpayers engaging in transactions with foreign related parties. This clarification is intended to prevent unintended consequences and ensure that taxpayers are not unfairly penalized for engaging in legitimate business transactions. Overall, the Foreign Tax Credit Protection Act seeks to promote fairness and transparency in the tax treatment of payments made to foreign related parties, while also providing certainty for taxpayers and reducing the risk of base erosion.
The bill seeks to address concerns regarding the treatment of payments made to foreign related parties for tax purposes. Specifically, it aims to ensure that payments made to foreign related parties that are subject to an adequate amount of foreign tax are not unfairly penalized or categorized as base erosion payments.
By making this amendment to the Internal Revenue Code, the bill aims to provide clarity and certainty for taxpayers engaging in transactions with foreign related parties. This clarification is intended to prevent unintended consequences and ensure that taxpayers are not unfairly penalized for engaging in legitimate business transactions. Overall, the Foreign Tax Credit Protection Act seeks to promote fairness and transparency in the tax treatment of payments made to foreign related parties, while also providing certainty for taxpayers and reducing the risk of base erosion.
Read the Full Bill
Current Status of Bill HR 1911
Bill HR 1911 is currently in the status of Bill Introduced since March 6, 2025. Bill HR 1911 was introduced during Congress 119 and was introduced to the House on March 6, 2025. Bill HR 1911's most recent activity was Referred to the House Committee on Ways and Means. as of March 6, 2025
Bipartisan Support of Bill HR 1911
Total Number of Sponsors
2Democrat Sponsors
2Republican Sponsors
0Unaffiliated Sponsors
0Total Number of Cosponsors
2Democrat Cosponsors
1Republican Cosponsors
1Unaffiliated Cosponsors
0Policy Area and Potential Impact of Bill HR 1911
Primary Policy Focus
Alternate Title(s) of Bill HR 1911
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.
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.
Comments

Ayla Boykin
30,036
10 months ago
This bill sucks, it's gonna mess with my money and I ain't happy about it.
Sponsors and Cosponsors of HR 1911
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