Providing for Congressional Disapproval Under Chapter 8 of Title United States Code, of the Rule Submitted By the Internal Revenue Service Relating to ``Interim Guidance Simplifying Application of the

Floor Speech

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Mr. WYDEN. Madam President, the Senate will vote very soon on a resolution I put forward to overturn a new Trump administration policy regarding corporate taxes and partnerships. When you start using a whole bunch of Washington lingo about the corporate alternative minimum tax and income allocated across partnerships, people go to sleep in a hurry, so I am going to explain it as simply as I can.

The Trump administration treats the U.S. Treasury Department like Make-A-Wish for corporations and private equity. Any giveaway or special treatment an ultrawealthy corporate executive can dream of, the Treasury Secretary and his crew are there to move Heaven and Earth to make it happen.

With respect to the resolution we are voting on today, the question is whether the most profitable corporations and private equity giants in America--those with profits north of $1 billion in a single year-- ought to pay a minimum tax--a minimum tax--of 15 percent. Now, keep in mind that 15 percent is roughly the tax rate you pay if you are a middle-income household--a nurse, a firefighter, or a couple of schoolteachers.

Democrats say those hugely profitable firms ought to pay a 15-percent minimum rate. The Trump administration and Senate Republicans say no. And since Republicans have unified control of government, the big corporations can get exactly what they want in America.

The Trump administration tore a giant hole in the minimum tax with a new policy change, a change that amounts to a $10.3 billion corporate handout--and that is according to the Joint Committee on Taxation.

Now, it has been the case for decades that these huge corporations play financial games to conceal their profits from the IRS. That is how they winnow down their tax rates to single digits--maybe even zero. The same goes for the private equity giants. They report to their shareholders and investors that profits are booming. Everybody celebrates. Share prices and executive comp go up. It is party time in the C-suite.

Then the financial chicanery and trickery begins. They fudge the math, and when it comes time to report earnings to the IRS, suddenly these corporations and private equity firms are out there hollering about poverty. Forget that they told the shareholders they were swimming in cash; suddenly, they claim they owe little to nothing in taxes.

This kind of tax rate gamesmanship is why Democrats created the corporate alternative minimum tax in 2022. The minimum tax has only been in place for a few years, but already corporations and the private equity crowd are trying to rip it to pieces, and clearly the Trump administration is helping.

The $10.3 billion handout never got any debate here on the floor of the Senate. It didn't even come from any legislation. The administration created it out of thin air. It is a hidden piece inside part of Federal rulemaking with a very deceptive bureaucratic name. It is IRS Notice 2025-28. And the topic is so bland, if you don't have a background in tax policy, you might not even catch on to what it is all about.

The notice rewrites the rules that govern how corporations and private equity firms count income from the partnerships they own. They get to pick from six different methods--six--for counting their cash, adding a whole lot of complexity to a part of the Tax Code that is already like root canal work just reading it. Essentially, these firms get to play a game of ``choose your own tax rate.'' I repeat: They can play a game of ``choose your own tax rate.''

The Trump policy encourages these giants to set up and abuse partnerships--layer after layer of redtape solely for the purpose of dodging taxes. It has nothing to do with creating jobs or launching new product lines or areas of investment; it is just a matter of moving money around on paper until you are able to make sure your taxes just go poof. These big, profitable corporations and private equity firms got a great deal from the Trump administration last year.

This debate is about a simple change in policy from the Treasury Department that handed them $10.3 billion. If you ask me, they have already gotten enough from the people in charge. The Trump administration and Republicans gave them $1 trillion in new tax breaks in the budget megabill they passed in July. Somehow, that wasn't enough.

The Trump administration junked an effort to crack down on another partisanship abuse, something known as basis shifting. That is when businesses dodge taxes by moving assets around from one operation to another. Again, this provides no value to our economy; it is just a big tax game. The Trump administration doesn't have any problem with that, so they put the green light to the tax games and said: OK, everybody, there is not going to be a crackdown.

That was worth $100 billion to these same corporations and private equity giants.

Today, I ask my colleagues: When is enough actually enough?

Millions and millions of families in Oregon and across the country struggle to get by, buried under the rising cost of living. Federal deficits shoot through the roof. The job market looks shaky. Young people tell us there is not any opportunity for them to get ahead. It is a slap in the face to all those Americans every time the Trump administration gives another handout to huge corporations and the ultrawealthy. They believe the system is rigged, and they are right. It is rigged because the Trump administration, as I said at the outset, treats the U.S. Treasury like Make-A-Wish for big corporations and private equity. The ultrawealthy and the megadonors get what they want; everybody else gets short shrift.

So the resolution I brought before the Senate today is better. This isn't about the Federal Government clobbering big corporations with big taxes. We are talking about a minimum contribution--a 15-percent tax rate that a lot of people wouldn't even consider to be actually a fair share for these big corporations. The biggest, most profitable corporations and private equity firms don't need a special carve-out. They don't need any more Trump giveaways.

So, today, I ask my colleagues to support this resolution. Let's block this latest handout to the megacorporations and private equity giants that really do not need it.

I yield and now move to proceed to Calendar No. 297, S.J. Res. 95.
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