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 bill, a foreign corporation would be treated as domestic if it would be a surrogate foreign corporation under a lowered 80 percent ownership threshold, or if, pursuant to a plan, it acquires substantially all the properties of a domestic corporation or domestic partnership and either former owners hold more than 50 percent of its stock or its management and control occurs primarily within the United States with significant domestic business activities. The bill also includes an exception for corporations with substantial business activities in their foreign country of organization, directs the Treasury Secretary to issue regulations on management and control and domestic business activity tests, and applies to taxable years ending after May 8, 2014.