,,ii  #aafth ,,congress  #b;d ,session  
,s4 #cbhj  ,,in ,,the ,,senate ,,of     
,,the ,,united ,,states  ,february #ab1 
#bjbj,mr4 ,wyden 7for himself and ,mr4  
,brown7 introduced the following bill2  
which was read twice and referred to the
 ,committee on ,finance  ,a ,,bill  ,to 
amend the ,internal ,revenue ,code of   
#aihf to clarify that high-taxed amounts
 are excluded from tested income for    
purposes of determining global          
intangible low-taxed income only if such
 amounts would be foreign base company  
income or insurance income4  #a4 ,short 
title ,this ,act may be cited as the    
,blocking ,new ,corporate ,tax          
,giveaways ,act4  #b4 ,clarification of 
amounts excluded from tested income  7a7
 ,in general ,section                   
#iea;,a7c77#b77;,a77i77,,iii7 of the    
,internal ,revenue ,code of #aihf is    
amended to read as follows3  7,,iii7 any
 gross income of such corporation-- 7aa7
 which1 without regard to section       
#ied7;b77#d71 is treated as foreign base

 company income 7as defined in section  
#ied7 or insurance income 7as defined in
 section #iec71 but  7bb7 which1 after  
the application of section #ied7;b77#d71
 is not so treated1  4  7b7 ,effective  
date ,the amendment made by this section
 shall apply to taxable years of foreign
 corporations beginning on or after the 
date of the enactment of this ,act1 and 
to taxable years of ,united ,states     
shareholders in which or with which such
 taxable years of foreign corporations  
end4