,,ii  #aaith ,,congress  #ast ,session  
,s4 #bjba  ,,in ,,the ,,senate ,,of     
,,the ,,united ,,states  ,june #aa1     
#bjbe ,mr4 ,wyden 7for himself1 ,mr4    
,warner1 ,mr4 ,warnock1 and ,mr4 ,welch7
 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 exclude round-tripped income   
for purposes of calculating global      
intangible low-taxed income1 and for    
other purposes4  #a4 ,short title ,this 
,act may be cited as the ,close the     
,round-,tripping ,loophole ,act4  #b4   
,modification to determination of net   
deemed intangible income return  7a7 ,in
 general ,section #iea;,a7b77#b77;,a7 of
 the ,internal ,revenue ,code of #aihf  
is amended--  7#a7 by striking #aj      
percent of the aggregate of and         
inserting #aj percent of the excess 7if 
any7 of--  7i7 the aggregate of  1 and  
7#b7 by adding at the end the following 
new clause3  7ii7 an amount equal to the

 product of the amount determined under 
clause 7i7 and the round-tripping ratio1
 over  4  7b7 ,round-,tripping ratio    
,section #iea;,a7b7 of the ,internal    
,revenue ,code of #aihf is amended by   
adding at the end the following new     
paragraph3  7#c7 ,round-tripping ratio  
,for purposes of this subsection-- 7,a7 
,in general ,the round-tripping ratio   
means1 with respect to any ,united      
,states shareholder for any taxable     
year1 the percentage 7not greater than  
#ajj percent7 which is equal to the     
ratio which--  7i7 the shareholder's    
round-tripped net ,,cfc tested income   
for such taxable year determined under  
subparagraph 7,b71 bears to  7ii7 the   
shareholder's net ,,cfc tested income   
for such taxable year1 determined       
without regard to this paragraph4  7,b7 
,shareholder's round-tripped net ,,cfc  
tested income ,for purposes of          
subparagraph 7,a77i71 a ,united ,states 
shareholder's round-tripped net ,,cfc   
tested income for any taxable year is   

the net ,,cfc tested income of such     
shareholder which would be determined   
under subsection 7c7 for such taxable   
year if-- 7i7 the only income taken into
 account under clause 7i7 of subsection 
7c77#b77;,a7 in determining the tested  
income or tested loss of each controlled
 foreign corporation taken into account 
by such shareholder under subsection    
7c77#a7 for such taxable year were      
income described in such clause which is
 derived in connection with--  7,i7     
property-- 7aa7 which is sold by the    
taxpayer to any person who is a ,united 
,states person1 or  7bb7 which the      
taxpayer cannot establish to the        
satisfaction of the ,secretary is for   
foreign use1 or  7,,ii7 services        
provided by the taxpayer which the      
taxpayer cannot establish to the        
satisfaction of the ,secretary are      
provided to any person1 or with respect 
to property1 not located within the     
,united ,states1 and  7ii7 the only     
deductions taken into account under     

clause 7ii7 of subsection 7c77#b77;,a7  
in determining such tested income or    
tested loss were deductions properly    
allocable to income described in clause 
7i74  7,c7 ,foreign use ,for purposes of
 this subsection1 the determination of  
whether property is for a foreign use   
shall be made in the same manner as     
under section #bej7;b74  7,d7 ,exception
 for certain small taxpayers  7i7 ,in   
general ,in the case of any ,united     
,states shareholder described in clause 
7ii71 the round-tripping ratio shall be 
#j percent4  7ii7 ,taxpayer described   
7,i7 ,in general ,a ,united ,states     
shareholder is described in this clause 
if the average annual gross receipts of 
such ,united ,states shareholder for the
 #c-taxable year period ending with the 
taxable year which precedes such taxable
 year does not exceed #ajj1jjj1jjj4     
7,,ii7 ,application of certain rules    
,rules similar to the rules of          
paragraphs 7#b77;,b7 and 7#c7 of section
 #ei;,a7e7 shall apply for purposes of  

this clause4  4  7c7 ,effective date    
,the amendments made by this section    
shall apply taxable years of foreign    
corporations beginning 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  #c4 ,limitation on deduction for  
global intangible low-taxed income  7a7 
,in general ,section #bej7;a77#a77;,b7  
of the ,internal ,revenue ,code of #aihf
 is amended to read as follows3  7,b7   
#ej percent of the excess 7if any7 of-- 
7i7 the sum of-- 7,i7 the global        
intangible low-taxed income amount 7if  
any7 which is included in the gross     
income of such domestic corporation     
under section #iea;,a for such taxable  
year1 and  7,,ii7 the amount treated as 
a dividend received by such corporation 
under section #gh which is attributable 
to the amount described in subclause    
7,i71 over  7ii7 an amount equal to the 
product of the amount determined under  

clause 7i7 and the round-tripping ratio 
7as determined under section            
#iea;,a7b77#c77 of such domestic        
corporation for such taxable year4  4   
7b7 ,effective date ,the amendment made 
by this section shall apply to taxable  
years beginning after the date of the   
enactment of this ,act4