The credit is barred for named and foreign influenced firms
What the document says“No credit shall be determined under subsection (a) for any taxable year beginning after the date of enactment of this paragraph if the taxpayer is a specified foreign entity (as defined in section 7701(a)(51)(B)).”
The section adds a new paragraph (3) to section 45U(c) of the Internal Revenue Code of 1986 barring the credit for a taxable year beginning after enactment where the taxpayer is a specified foreign entity as defined in section 7701(a)(51)(B), and for a taxable year beginning more than two years after enactment where the taxpayer is a foreign-influenced entity as defined in section 7701(a)(51)(D) read without clause (i)(II).
What the document actually says“No credit shall be determined under subsection (a) for any taxable year beginning after the date of enactment of this paragraph if the taxpayer is a specified foreign entity (as defined in section 7701(a)(51)(B)).”
No credit is given to a named foreign body. That holds for tax years starting after this law.
A second bar covers a foreign influenced body. That one starts two years later. Both terms come from the tax code.
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