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 exclude certain payments made to foreign subsidiaries or affiliates from being classified as "base erosion payments" (payments that reduce U.S. tax revenue). It applies specifically to multinational corporations making cross-border payments to foreign entities that pay at least 15% effective foreign income tax. To qualify, companies must prove the foreign entity’s tax rate meets the threshold using standard financial statements with adjustments for items like dividends or currency gains. The policy change aims to prevent double taxation on such payments while maintaining anti-avoidance safeguards.