To amend the Internal Revenue Code of 1986 to limit the interest deduction of foreign corporations that hold interests of less than ten percent in partnerships engaged in business in the United States.

Amends the Internal Revenue Code to require that a foreign corporation be treated as owning (or as having incurred) a pro rata share of the assets and liabilities of a partnership in which it is a partner for purposes of allocating interest deductions (thus barring such deductions on the basis of gross income).