To amend the Internal Revenue Code of 1986 to provide that certain payments to foreign related parties subject to sufficient foreign tax are not treated as base erosion payments.

This bill modifies U.S. tax rules to prevent certain cross-border payments from being classified as "base erosion payments" (which reduce U.S. tax revenue). It applies to U.S. companies paying foreign affiliates, specifically if the foreign recipient pays at least 15% effective foreign income tax on the payment amount. The key provision allows these payments to be excluded from base erosion calculations if the taxpayer proves the foreign tax rate meets the 15% threshold using financial statements with specified adjustments. This creates a clearer path for multinational corporations to deduct payments to foreign entities that already bear substantial foreign tax burdens.