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S. 2786

Corporate Inverters Earnings Stripping Reform Act of 2014

Corporate Inverters Earnings Stripping Reform Act of 2014 - Amends the Internal Revenue Code to impose limitations on the tax deduction for interest paid by corporations which are designated as applicable entities (i.e., members of an expanded affiliated group which includes a surrogate foreign corporation which is not treated as a domestic corporation). Prohibits such an entity from claiming a tax deduction for interest that exceeds 25% of its adjusted taxable income and from carrying forward interest which is paid or accrued during the first year in which such entity becomes an applicable entity.

Requires an applicable entity to file an annual application for an approval agreement (i.e., a prefiling, advance pricing, or other agreement involving a related-party transaction) with the Internal Revenue Service (IRS) during the 10-year period after it becomes an applicable entity.

Read twice and referred to the Committee on Finance.

Sen. Schumer, Charles E. [D-NY](D-NY)Sponsor
14 cosponsors14 D
14cosponsors1committees2actions5subjects
  • Introduced in SenateSep 10, 2014
  1. IntroReferral

    Read twice and referred to the Committee on Finance.

  2. IntroReferral10000

    Introduced in Senate