To amend the Internal Revenue Code of 1986 to prevent corporations from exploiting tax treaties to evade taxation of United States income.

[AI summary unavailable — showing source text] Amends the Internal Revenue Code to prohibit a reduction under any treaty of the United States of tax withholding for a tax deductible payment made between persons who are members of the same foreign controlled group of entities unless there would be a similar reduction for payments made directly to the foreign parent corporation of such entities.…