Stop Corporate Inversions Act of 2026

The bill amends Section 7874 of the Internal Revenue Code to treat certain foreign corporations as domestic corporations for federal tax purposes. Under the revised rules, a foreign corporation is treated as domestic if an ownership threshold of 80 percent (instead of 60 percent) is met, or if it is an "inverted domestic corporation," meaning former shareholders or partners of a domestic entity hold more than 50 percent of the combined entity or its management and control occurs primarily in the United States with significant domestic business activities. Exceptions apply where the expanded affiliated group has substantial business activities in the foreign country of organization, and the Treasury Secretary is directed to issue regulations, with amendments applying to taxable years ending after May 8, 2014.

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