OBBBA Hugo DemoA live demo of DiscussionBridge for Hugo

Topic index

Connected OBBBA topics

These native Hugo pages are generated from the authenticated forum-scale connection. Later source-topic changes reuse the same durable Bridge identity and destination URL.

Browse the source forum

Sec. 70423. Permanent extension of new markets tax credit

(a) In general.—Section 45D(f)(1)(H) is amended by striking “for for each of calendar years 2020 through 2025” and inserting “ for each calendar year after 2019”. (b) Carryover of unused limitation.—Section 45D(f)(3) is …

Sec. 70402. Enhancement of adoption credit

(a) In general.—Section 23(a) is amended by adding at the end the following new paragraph: “(4) PORTION OF CREDIT REFUNDABLE.—So much of the credit allowed under paragraph (1) as does not exceed $5,000 shall be treated …

PART V—OTHER INTERNATIONAL TAX REFORMS

SEC. 70351. Permanent extension of look-thru rule for related controlled foreign corporations. (a) In general.—Section 954(c)(6)(C) is amended by striking “and before January 1, 2026,”. (b) Effective date.—The amendment …

Sec. 70354. Modifications to pro rata share rules

(a) In general.—Subsection (a) of section 951 is amended to read as follows: “(a) Amounts included.— “(1) IN GENERAL.—If a foreign corporation is a controlled foreign corporation at any time during a taxable year of the …

PART IV—BUSINESS INTEREST LIMITATION

SEC. 70341. Coordination of business interest limitation with interest capitalization provisions. (a) In general.—Section 163(j) is amended by redesignating paragraphs (10) and (11) as paragraphs (11) and (12) and by …

PART III—BASE EROSION MINIMUM TAX

SEC. 70331. Extension and modification of base erosion minimum tax amount. (a) In general.—Section 59A(b) is amended— (1) by striking “10 percent” in paragraph (1) and inserting “10.5 percent”, and (2) by striking …

Sec. 70323. Rules related to deemed intangible income

(a) Taxation of net CFC tested income.— (1) IN GENERAL.—Section 951A(a) is amended by striking “global intangible low-taxed income” and inserting “net CFC tested income”. (2) REPEAL OF TAX-FREE DEEMED RETURN ON FOREIGN …

Sec. 70322. Determination of deduction eligible income

(a) Sales or other dispositions of certain property.— (1) IN GENERAL.—Section 250(b)(3)(A)(i) is amended— (A) by striking “and” at the end of subclause (V), (B) by striking “over” at the end of subclause (VI) and …

PART I—FOREIGN TAX CREDIT

SEC. 70311. Modifications related to foreign tax credit limitation. (a) Rules for allocation of certain deductions to foreign source net CFC tested income for purposes of foreign tax credit limitation.—Section 904(b) is …