H.R. 1911 — 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 section establishes an exception to base erosion payments under the base erosion anti-abuse tax (BEAT)—which imposes a minimum tax on certain large domestic corporations for deductible payments (e.g., interest, royalties) to foreign affiliates exceeding thresholds—by excluding amounts paid to foreign related parties if both the recipient and the amount are subject to an effective rate of foreign income tax of at least 15%, as determined using applicable financial statements with specified adjustments. It directs the Secretary of the Treasury to issue regulations on calculating the effective rate and preventing abuse (e.g., recharacterizing transactions), applicable to taxable years beginning after enactment.