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HR 2423
Introduced Re-checks Congress.gov for new actions and updates the bill's status, and fills in any sponsors, committees, or related bills that are missing. It does not re-pull sponsors/cosponsors/committees/related — those rarely change — and it skips all work if nothing has changed upstream, so it's cheap to click.

Unfair Tax Prevention Act

To amend the Internal Revenue Code of 1986 to modify the application of the base erosion and anti-abuse tax with respect to certain entities connected to jurisdictions which have implemented an extraterritorial tax.

Introduced Mar 27, 2025

Latest action (Mar 27, 2025) Referred to the House Committee on Ways and Means.

Referred to
Ways and Means Committee
Policy area
Taxation
Issues
Economy & Taxes

Summary

This bill amends the Internal Revenue Code to modify the base erosion and anti-abuse tax (BEAT) rules for certain U.S. entities controlled by foreign corporations located in countries with extraterritorial tax regimes. The bill targets entities owned by foreign entities in jurisdictions that impose taxes based on income or profits connected to a foreign corporation through ownership chains, regardless of direct ownership interests. For these entities, the bill treats them as applicable taxpayers subject to BEAT, moves the threshold date to the date of enactment, and requires 50 percent of the entity's cost of goods sold to be treated as a base erosion tax benefit. The bill removes certain exemptions and deferrals that would otherwise apply to these entities. The changes apply to taxable years beginning after the date of enactment.

AI-generated plain-language summary of the bill text — neutral, and may be imperfect. See the full text below for the exact wording.

Sponsor (1)
24 cosponsors

Money behind the sponsor

Top reported contributors to Ron Estes’s campaign committee (2024 cycle) — who funds the bill’s sponsor, not a claim about this bill. Data from FEC.

  • TRANSYSTEMS $21,650
  • WATCO $13,200
  • NULL $11,600
  • BERGEN PAIN MANAGEMENT PC $9,900
  • ASH BROKERAGE $7,061

Organizations whose employees gave the most — itemized individual contributions grouped by the donor’s reported employer (FEC Schedule A). Full finance for Ron Estes → · Outside spending →

Actions (2)
  1. Mar 27, 2025 Referred to the House Committee on Ways and Means. · house
  2. Mar 27, 2025 Introduced in House

Similar bills (6)

Bills with similar text or summary — includes reintroductions across Congresses. Ranked by semantic similarity of the bill text (computed locally); a neutral discovery aid, not a claim the bills are duplicates.

  • HR 4826 — Cutting Paperwork for Taxpayers Act · Introduced Jul 29, 2025 · Cong. 119 73%
  • S 2358 — IRS Accountability and Taxpayer Protection Act · Introduced Jul 21, 2025 · Cong. 119 73%
  • HR 2802 — Tax Relief from Tariffs and High Costs Act · Introduced Apr 9, 2025 · Cong. 119 73%
  • HR 801 — Charitable Act · Introduced Jan 28, 2025 · Cong. 119 72%
  • HR 232 — SALT Fairness and Marriage Penalty Elimination Act · Introduced Jan 7, 2025 · Cong. 119 72%
  • HR 1091 — Carried Interest Fairness Act of 2025 · Introduced Feb 6, 2025 · Cong. 119 72%

Text versions (1)
  • Introduced in House · Mar 27, 2025

Only one text version is on file, so there’s no earlier version to compare against yet.

Full text

IN THE HOUSE OF REPRESENTATIVES

March 27, 2025

Mr. Estes (for himself, Mr. Buchanan, Mr. Smith of Nebraska, Mr. Kelly of Pennsylvania, Mr. Schweikert, Mr. LaHood, Mr. Arrington, Mr. Smucker, Mr. Hern of Oklahoma, Mrs. Miller of West Virginia, Mr. Murphy, Mr. Kustoff, Mr. Fitzpatrick, Mr. Steube, Ms. Tenney, Mrs. Fischbach, Mr. Moore of Utah, Ms. Van Duyne, Mr. Feenstra, Ms. Malliotakis, Mr. Carey, Mr. Yakym, Mr. Miller of Ohio, Mr. Bean of Florida, and Mr. Moran) introduced the following bill; which was referred to the Committee on Ways and Means

A BILL

To amend the Internal Revenue Code of 1986 to modify the application of the base erosion and anti-abuse tax with respect to certain entities connected to jurisdictions which have implemented an extraterritorial tax.

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

This Act may be cited as the “Unfair Tax Prevention Act”.

SEC. 2. APPLICATION OF THE BASE EROSION AND ANTI-ABUSE TAX WITH RESPECT TO CERTAIN ENTITIES CONNECTED TO EXTRATERRITORIAL TAX JURISDICTIONS.

(a) In General.—Section 59A of the Internal Revenue Code of 1986 is amended by redesignating subsection (i) as subsection (j) and inserting after subsection (h) the following new subsection:

“(i) Special Rules for Foreign-Owned Extraterritorial Tax Regime Entities.—

“(1) In general.—In the case of any foreign-owned extraterritorial tax regime entity—

“(A) such entity shall be treated as described in subparagraphs (B) and (C) of subsection (e)(1) for purposes of determining whether such entity is an applicable taxpayer,

“(B) subsection (b)(2) shall be applied by substituting ‘the date of the enactment of subsection

(i)’ for ‘December 31, 2025’,

“(C) subsections (c)(2)(B), (c)(4)(B)(ii), and

(d)(5) shall not apply, and

“(D) 50 percent of such entity’s cost of goods sold shall be treated as a base erosion tax benefit with respect to a base erosion payment.

“(2) Foreign-owned extraterritorial tax regime entity.— For purposes of this subsection—

“(A) In general.—The term ‘foreign-owned extraterritorial tax regime entity’ means any taxpayer which is controlled by a foreign entity (other than a foreign entity controlled by any domestic corporation) if an extraterritorial tax is imposed on any of the following entities:

“(i) Any foreign entity which controls the taxpayer.

“(ii) Any foreign entity which is controlled by—

“(I) the taxpayer, or

“(II) any foreign entity described in clause (i).

“(iii) Any trade or business of any foreign entity described in clause (i) or (ii).

“(B) Extraterritorial tax.—

“(i) In general.—The term ‘extraterritorial tax’ means any tax imposed by a foreign country on a corporation (including any trade or business of such corporation) which is determined by reference to any income or profits received by any person (including any trade or business of any person) by reason of such person being connected to such corporation through any chain of ownership, determined without regard to the ownership interests of any individual, and other than by reason of such corporation having a direct or indirect ownership interest in such person.

“(ii) Tax.—The term ‘tax’ includes any increase in tax whether effectuated by an increase in the rate or base of a tax, by a denial of deductions or credits, or otherwise.

“(C) Foreign entity.—The term ‘foreign entity’ means any foreign person other than an individual.

“(D) Control.—Control has the same meaning given such term under section 954(d)(3).”.

(b) Effective Date.—The amendment made by this section shall apply to taxable years beginning after the date of the enactment of this Act. <all>

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