U.S. companies that make billions of dollars from patents and other intellectual property held offshore would be eligible for a special 12.5% tax rate on those earnings under the Senate tax plan.

That's a potential "gold mine" for some multinationals, said Michael Mundaca, co-director of Ernst & Young's National Tax Practice—especially compared to international tax provisions in the House bill that generally would apply a top rate of 20%.

But it's unclear which chamber's vision will prevail—and some companies that now pay even lower rates on such income may oppose the measure regardless.

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