H.R. 10431

U.S. Innovation and Global Competitiveness Act of 2026

Sponsor: Ron Estes · 0 cosponsors

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Where it stands

Introduced Sep 16
Committee Now
House of Representatives —
Senate —
Law —

Introduced Sep 16
Committee Now
House of Representatives —
Senate —
Law —

Referred to the House Committee on Ways and Means. (Sep 16)

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Text of the bill

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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

(a) In General. Section 960(d) is amended—

(1) by amending paragraph (1) to read as follows:

Text this section adds to the law

(1) In general. For purposes of subpart A of this part, if any amount is includible in the gross income of a domestic corporation under section 951A, such domestic corporation shall be deemed to have paid foreign income taxes equal to the aggregate tested foreign income taxes paid or accrued by controlled foreign corporations of such corporation.

, and

(2) by striking paragraph (2).

(b) Effective date. The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2026, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end.

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