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This bill would change federal tax rules so that U.S. taxpayers cannot use a foreign tax credit, and in some cases cannot take a tax deduction, for taxes paid to the Russian Federation. In simple terms, it would stop people and businesses from reducing their U.S. taxes by counting certain taxes paid to Russia. The rule would start after the bill becomes law and would stay in place until U.S. tariff treatment of Russian products is restored under another law. The bill also says these changes would apply even if a tax treaty would normally say otherwise.
- The foreign tax credit ban would apply to Russia starting 30 days after the bill is enacted.
- The deduction limit would begin later, for taxes paid or owed after 90 days from enactment.
- The rules would remain in effect until the date when normal tariff rates for Russian products are restored under the separate law referenced in the bill.
- The bill says it overrides any conflicting treaty obligation of the United States.
Official Summaries
Hindering Oppressive Nations from Obtaining Revenue Act or HONOR Act
This bill prohibits a taxpayer from claiming the foreign tax credit (FTC) or an itemized tax deduction for taxes paid, accrued, or deemed paid to Russia.
Under current law, a taxpayer may claim the FTC for income, war profits, and excess profits taxes (or taxes imposed in lieu of these taxes) paid, accrued, or deemed paid to a foreign country (and certain U.S. possessions) or an itemized tax deduction for such taxes, both subject to limitations.
However, under current law, a taxpayer may not claim the FTC (but may claim an itemized tax deduction) for taxes paid to a foreign country if (1) the United States does not recognize the country’s government, (2) the United States severs or does not conduct diplomatic relations with the country, or (3) the country is designated by the Department of State as supporting international terrorist acts. (Currently, the FTC is disallowed for taxes paid, accrued, or deemed paid to Iran, North Korea, Sudan, and Syria.)
Under the bill, a taxpayer may not claim the FTC for taxes paid, accrued, or deemed paid to Russia beginning 30 days after the date of enactment and until normal U.S. trade relations with Russia are restored (pursuant to requirements established by the Suspending Normal Trade Relations with Russia and Belarus Act).
The bill also disallows an itemized tax deduction for taxes paid, accrued, or deemed to be paid to Russia (effective 90 days after the date of enactment).
Current Full Text
[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[S. 327 Engrossed in Senate (ES)]
<DOC>
119th CONGRESS
2d Session
S. 327
_______________________________________________________________________
AN ACT
To amend the Internal Revenue Code of 1986 to deny any foreign tax
credit or deduction with respect to taxes paid or accrued to the
Russian Federation.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ``Hindering Oppressive Nations from
Obtaining Revenue Act'' or ``HONOR Act''.
SEC. 2. DENIAL OF FOREIGN TAX CREDIT WITH RESPECT TO THE RUSSIAN
FEDERATION.
(a) In General.--Section 901(j)(2) of the Internal Revenue Code of
1986 is amended by adding at the end the following new subparagraph:
``(C) Special rule for russia.--
``(i) In general.--This subsection shall
apply to the Russian Federation during the
period described in clause (ii).
``(ii) Period of application.--The period
described in this clause with respect to any
country is the period--
``(I) beginning on the date that is
30 days after the date of the enactment
of this subparagraph, and
``(II) ending on the date on which
the resumption of the application of
the rates of duty set forth in column 1
of the Harmonized Tariff Schedule of
the United States to products of that
country takes effect pursuant to
section 4(b) of the Suspending Normal
Trade Relations with Russia and Belarus
Act.''.
(b) Deduction Denied.--Section 901(j)(3) of such Code is amended by
adding at the end the following new sentence: ``The preceding sentence
shall not apply to any tax of any country to which paragraph (2)(C)
applies.''.
(c) Effective Dates.--
(1) In general.--Except as provided in paragraph (2), the
amendments made by this section shall take effect on the date
of the enactment of this Act.
(2) Deduction limitation.--The amendment made by subsection
(b) shall apply to taxes paid or accrued (or deemed paid or
accrued under section 960 of the Internal Revenue Code of 1986)
after the date that is 90 days after the date of the enactment
of this Act.
(3) Nonapplication of treaty rules.--This section and the
amendments made by this section shall be applied without regard
to any treaty obligation of the United States.
Passed the Senate March 10, 2026.
Attest:
Secretary.
119th CONGRESS
2d Session
S. 327
_______________________________________________________________________
AN ACT
To amend the Internal Revenue Code of 1986 to deny any foreign tax
credit or deduction with respect to taxes paid or accrued to the
Russian Federation.