Unfair Tax Prevention Act

HR 2423, the Unfair Tax Prevention Act, amends the U.S. tax code to modify how the base erosion tax applies to certain foreign-owned businesses. It directly affects foreign-controlled entities operating under specific foreign tax systems that impose taxes based on ownership chains, such as those linked to foreign corporations. Key provisions include treating these entities as "applicable taxpayers" for tax purposes, changing a deadline from December 31, 2025, to the bill's enactment date, and counting 50% of their cost of goods sold as a tax benefit while excluding certain other tax rules. The changes apply to taxable years beginning after the bill becomes law.