International Competition for American Jobs Act

The International Competition for American Jobs Act (S 1605) modifies U.S. tax rules for multinational corporations, primarily affecting U.S. shareholders of foreign corporations and foreign corporations themselves. Key provisions include extending the "look-thru rule" for controlled foreign corporations, changing how deductions for foreign-derived income are calculated, and modifying the base erosion minimum tax. The bill also alters how foreign tax credits are applied, eliminates certain inclusions of foreign income, and creates special rules for Virgin Islands services income. Most provisions apply to taxable years beginning after December 31, 2025.