Deterring Adversarial Access to Americans’ Data Act
Summary
What This Bill Does
This bill changes the Internal Revenue Code to make use of foreign adversary-controlled technology costly for federal tax purposes. It expands the prohibited foreign entity framework to include entities using technology designed, developed, manufactured, provided by, dependent on, or interoperable with technology from specified foreign or foreign-influenced entities. It also denies bonus depreciation for foreign adversary-controlled technology or property owned by prohibited foreign entities, denies section 174A treatment for acquisition or development of that technology or spending by prohibited foreign entities, changes business-interest calculations for income, gain, deductions, or losses tied to the technology or prohibited foreign entities, and denies the research credit to specified foreign entities or foreign-influenced entities. The changes apply to taxable years beginning more than 1 year after enactment.
Who Benefits and How
U.S. technology competitors, national-security agencies, and taxpayers concerned about adversary access to Americans' data benefit because the bill removes tax preferences for businesses relying on foreign adversary-controlled information and communications technology. The Internal Revenue Service gains explicit regulatory authority for the bonus-depreciation restrictions.
Who Bears the Burden and How
Taxpayers using foreign adversary-controlled technology, prohibited foreign entities, specified foreign entities, and foreign-influenced entities lose access to tax preferences and must track technology dependencies for compliance. The IRS must issue regulations, and affected businesses must adjust depreciation, research-expense, interest-limitation, and research-credit positions.
Key Provisions
- Adds foreign adversary-controlled technology to the prohibited foreign entity tax framework.
- Bars bonus depreciation for foreign adversary-controlled technology and property owned by prohibited foreign entities.
- Denies section 174A research-cost treatment for acquisition or development of foreign adversary-controlled technology and for spending by prohibited foreign entities.
- Modifies business-interest calculations for items attributable to foreign adversary-controlled technology or prohibited foreign-entity businesses.
- Prohibits research credits for specified foreign entities and foreign-influenced entities for taxable years beginning more than 1 year after enactment.
Evidence Chain:
This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.
At a Glance
What This Bill Does
Denies specified federal tax benefits for foreign adversary-controlled technology and prohibited foreign entities by changing entity classification, bonus depreciation, research expensing, business-interest rules, and R&D credits.
Key Policy Areas
Tax, Technology, National Security
Primary Purpose
Denies specified federal tax benefits for foreign adversary-controlled technology and prohibited foreign entities by changing entity classification, bonus depreciation, research expensing, business-interest rules, and R&D credits.
Policy Domains
Substantive provisions
Identified Gains
- U.S. technology competitors
- Internal Revenue Service
- National security agencies
- U.S. taxpayers avoiding adversary technology
Identified Costs
- Taxpayers using foreign adversary-controlled technology
- Prohibited foreign entities
- Specified foreign entities
- Foreign-influenced entities
- Internal Revenue Service
Legislative Progress
In CommitteeReferred to the House Committee on Ways and Means.
Introduced in House
Mr. Moran introduced the following bill; which was referred to …
Stakeholder Effects
cui bono?How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.
Taxpayers using foreign adversary-controlled technology, U.S. technology competitors
Positive-direction: U.S. technology competitors
Negative-direction: Taxpayers using foreign adversary-controlled technology
Prohibited foreign entities, Specified foreign entities
Bill Structure & Actor Mappings
Who is "The Secretary" in each section?
- "secretary"
- → Secretary of the Treasury
- "foreign_adversary_controlled_technology"
- → Information and communications technology or service tied to specified foreign or foreign-influenced entities
We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.
Learn more about our methodology