H.R. 10431
U.S. Innovation and Global Competitiveness Act of 2026
Sponsor: Ron Estes · 0 cosponsors
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Text of the bill
(a) Increase in deduction. Section 250(a)(1)(A) is amended by striking 33.34 percent and inserting 40 percent.
(b) Deduction not To apply against dividends received deduction limitation. Section 246(b)(1) is amended by striking subsection (a) and (b) of section 245, and section 250 the first place it appears and inserting and subsections (a) and (b) of section 245.
(c) Deduction taken into account in determining net operating loss deduction. Section 172(d) is amended by striking paragraph (9).
(d) Look-Through for interest payments. Section 250(b)(2) is amended by adding at the end the following new subparagraph:
(F) Interest paid by controlled foreign corporation. Foreign-derived deduction eligible income shall include interest paid by a controlled foreign corporation to a corporation that is a United States shareholder with respect to such foreign corporation if such controlled foreign corporation is related (within the meaning of section 954(d)) to such United States shareholder and such interest is an amount which is described in section 951A(c)(2)(A)(ii) with respect to such controlled foreign corporation. To the extent provided by the Secretary in regulations, the preceding sentence shall not apply to interest paid by a controlled foreign corporation to a related United States shareholder if such interest is directly related to interest expense of such shareholder (or another related person).
(e) Effective date. The amendments made by this section shall apply to taxable years beginning after December 31, 2026.