PolicyBrief
S. 327
119th CongressJan 30th 2025
Hindering Oppressive Nations from Obtaining Revenue Act
IN COMMITTEE

The "HONOR Act" denies foreign tax credits and deductions for taxes paid to the Russian Federation, starting shortly after enactment and lasting until normal trade relations are restored. This overrides any existing treaty obligations of the U.S.

Catherine Cortez Masto
D

Catherine Cortez Masto

Senator

NV

LEGISLATION

HONOR Act: New Bill Slashes Tax Breaks for Companies Doing Business with Russia

The HONOR Act (Hindering Oppressive Nations from Obtaining Revenue Act) directly targets the financial benefits companies get from operating in Russia. Specifically, the bill eliminates foreign tax credits for any taxes paid to the Russian Federation. It also prevents companies from deducting these taxes on their U.S. tax returns. The main goal? To ramp up economic pressure on Russia by cutting off a significant financial flow.

Tax Time Shake-Up

This bill changes the game for companies with operations in Russia. Starting 30 days after enactment, they can no longer claim foreign tax credits for taxes paid to Russia. What does this mean in practice? Imagine a U.S.-based tech firm with a branch in Moscow. Previously, they could offset their U.S. tax bill with taxes paid in Russia. Under the HONOR Act, that's no longer an option. The same goes for deductions – any taxes paid or accrued in Russia 90 days after enactment can't be written off. This could mean higher tax bills for these companies, effectively making it more expensive to do business in Russia. (SEC. 2).

Overriding Treaties and Long-Term Implications

One of the most significant aspects of the HONOR Act is that it overrides any existing treaty obligations between the U.S. and Russia (SEC. 2). This means that even if a treaty previously allowed for these tax benefits, the HONOR Act shuts them down. This provision underscores the seriousness of the U.S.'s stance. The measures will remain in place until normal trade relations with Russia are restored, as determined by the Suspending Normal Trade Relations with Russia and Belarus Act. This links the tax penalties directly to broader trade policy, providing a clear condition for lifting the restrictions.

Real-World Challenges

While the bill aims to tighten the economic screws on Russia, it also presents some practical challenges. Companies might try to find ways around these restrictions, potentially reclassifying payments to avoid the tax hit. It also raises the possibility of retaliatory measures from Russia, which could impact U.S. companies operating there. The effectiveness of the bill will depend on how strictly these provisions are enforced and how companies adapt to the new rules.