,i  #aaeth ,,congress  #b;d ,session    
,h4 ,r4 #fjae  ,,in ,,the ,,house ,,of  
,,representatives  ,june #f1 #bjah,mr4  
,de,fazio 7for himself1 ,mr4 ,doggett1  
,ms4 ,de,lauro1 ,ms4 ,norton1 and ,ms4  
,schakowsky7 introduced the following   
bill2 which was referred to the         
,committee on ,ways and ,means  ,a      
,,bill  ,to amend the ,internal ,revenue
 ,code of #aihf to increase the tax on  
certain global intangible income4  #a4  
,short title ,this ,act may be cited as 
the ,per-,country ,minimum ,act4  #b4   
,increase in tax on global intangible   
income  7a7 ,in general  7#a7 ,reduction
 in deduction for taxable years before  
#bjbf ,section #bej7;a77#a77;,b7 of the 
,internal ,revenue ,code of #aihf is    
amended by striking #ej percent and     
inserting #cg4e percent4  7#b7          
,reduction in deduction for taxable     
years after #bjbe ,section              
#bej7;a77#c77;,b7 of such ,code is      
amended to read as follows3  7,b7       
#ba4hge percent for #cg4e percent in    

subparagraph 7,b74  4  7b7 ,repeal of   
tax-,free deemed return on investments  
7#a7 ,in general ,section #iea;,a7a7 of 
such ,code is amended by striking global
 intangible low-taxed income and        
inserting net ,,cfc tested income4  7#b7
 ,conforming amendments  7,a7 ,section  
#iea;,a of such ,code is amended by     
striking subsections 7b7 and 7d74  7,b7 
,section #iea;,a7e77#a7 of such ,code is
 amended by striking subsections 7b71   
7c77#a77;,a71 and and inserting         
subsections 7c77#a77;,a7 and4  7,c7     
,section #iea;,a7f7 of such ,code is    
amended to read as follows3  7f7        
,treatment as subpart ,f income for     
certain purposes  7#a7 ,in general      
,except as provided in paragraph 7#b71  
any net ,,cfc tested income included in 
gross income under subsection 7a7 shall 
be treated in the same manner as an     
amount included under section           
#iea7;a77#a77;,a7 for purposes of       
applying sections #afh7;h77#b77;,b71    
#ece7;b77#aj71 #hea7;b71 #ijd7;h77#a71  

#iei1 #ifa1 #ifb1 #iic7;a77#a77;,e71    
#iif7;f77#a71 #abdh7;b77#a71            
#abdh7;d77#a71 #feja7;e77#a77;,c71      
#ffed7;d77#b77;,d71 and #ffee7;e77#d74  
7#b7 ,exception ,the ,secretary shall   
provide rules for the application of    
paragraph 7#a7 to other provisions of   
this title in any case in which the     
determination of subpart ,f income is   
required to be made at the level of the 
controlled foreign corporation4  4  7,d7
 ,section #ifj7;d77#b77;,a7 of such     
,code is amended by striking global     
intangible low-taxed income 7as defined 
in section #iea;,a7b77 and inserting net
 ,,cfc tested income 7as defined in     
section #iea;,a7c774  7c7 ,determination
 of net ,,cfc tested income on          
country-by-,country basis ,section      
#iea;,a of such ,code is amended by     
adding at the end the following3  7g7   
,determination made on                  
country-by-,country basis  7#a7 ,in     
general ,this section shall be applied  
with respect to a ,united ,states       

shareholder of the controlled foreign   
corporation separately with respect to  
each foreign country in which the       
controlled foreign corporation conducts 
any trade or business4  7#b7 ,special   
rules  7,a7 ,in general ,for purposes of
 making country-by-country              
determinations under this section and   
sections #ijd and #ifj with respect to  
net ,,cfc tested income for a taxable   
year pursuant to paragraph 7#a7--  7i7  
taxes paid or accrued to a foreign      
country by the controlled foreign       
corporation shall be assigned to that   
country1 and  7ii7 earnings to which    
such taxes relate shall be treated as   
income assigned to the country to which 
those tax payments are made4  7,b7      
,earnings assigned to two or more       
countries ,if the same earnings are     
assigned to two or more countries under 
subparagraph 7,a71 for purposes of      
paragraph 7#a7 such earnings and the    
taxes related thereto shall be treated  
as assigned to the country with the     

highest statutory corporate tax rate4   
7#c7 ,earnings not subject to tax ,if   
earnings are not subject to tax by any  
country1 then with respect to those     
earnings paragraph 7#a7 shall not apply4
  7#d7 ,regulations ,the ,secretary     
shall prescribe such regulations as may 
be necessary or appropriate to carry out
 this subsection1 including the time    
period in which foreign earnings and the
 associated foreign taxes are assigned  
to a country4  4  7d7 ,effective date   
,the amendments made by this section    
shall apply with respect to taxable     
years of controlled foreign corporations
 beginning after ,december #ca1 #bjah1  
and to taxable years of ,united ,states 
shareholders in which or with which such
 taxable years of foreign corporations  
end4