U.S. Innovation and Global Competitiveness Act of 2026

(a) Short title. This Act may be cited as the U.S. Innovation and Global Competitiveness Act of 2026.

(b) Amendment of 1986 code. Except as otherwise expressly provided, whenever in this Act an amendment or repeal is expressed in terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1986.

(c) Table of contents. The table of contents for this Act is as follows: Sec. 1. Short title, etc. Sec. 2. Modification of deduction for foreign-derived intangible income and net controlled foreign corporation tested 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 corporation tested income. Sec. 8. Repeal of inclusion percentage applicable to deemed paid credit for taxes properly attributable to tested income. Sec. 9. Application of foreign-source dividend deduction to amounts received by controlled foreign corporations. Sec. 10. Elimination of inclusion of foreign base company sales income and foreign base company services income. Sec. 11. Corporations exempt from subpart F inclusion for investment in United States property. Sec. 12. Special rules for transfers of intangible property from controlled foreign corporations to United States shareholders. Sec. 13. Net CFC tested income determined without regard to certain income derived from services performed in the United States Virgin Islands. Sec. 14. Repeal of modification to definition of adjusted taxable income for purposes of the limitation on business interest. Sec. 15. Research credit treated as a specified credit for all taxpayers for purposes of general business credit. Sec. 16. Regulations to prevent duplicative charges to capital account for certain research and development expenditures.