US SB1605

Permanently extends the "look-thru rule" for controlled foreign corporations (CFCs), removing the January 1, 2026 expiration date for Section 954(c)(6)(C)

Increases tax deductions for foreign-derived income to 37.5% and global intangible low-taxed income (GILTI) to 50%, while limiting expense apportionment to directly related expenses only

Modifies the Base Erosion and Anti-Abuse Tax (BEAT) by setting the minimum tax at 10% of modified taxable income, allowing general business credits against BEAT, and exempting payments to foreign recipients subject to at least 18.9% effective foreign tax rate

Simplifies foreign tax credit rules by eliminating the passive category and foreign branch income baskets, repealing the 80% GILTI foreign tax credit haircut, and allowing carryover of net CFC tested losses

Eliminates foreign base company sales and services income from subpart F inclusions, exempts corporations from subpart F inclusion for U.S. property investments, and creates tax-free treatment for distributions of intangible property from CFCs to U.S. shareholders within three years of enactment