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US SB3847
Bill
AI Summary
- Amends Internal Revenue Code section 7874 to treat foreign corporations as domestic corporations for tax purposes if former U.S. shareholders hold more than 50% of stock after acquisition (lowered from 80% threshold)
- Expands definition of "inverted domestic corporation" to include entities where management and control occurs primarily within the United States and the group has significant domestic business activities
- Defines "significant domestic business activities" as having at least 25% of employees, compensation, assets, or income based in or derived from the United States
- Provides exception for corporations with substantial business activities in their foreign country of organization compared to total group activities
- Applies retroactively to taxable years ending after May 8, 2014
Legislative Description
Stop Corporate Inversions Act of 2026
Taxation
Last Action
Read twice and referred to the Committee on Finance. (text: CR S579-580)
2/11/2026
Committee Referrals
Finance2/11/2026
Full Bill Text
No bill text available