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No Tax Breaks for Outsourcing Act

This bill amends the Internal Revenue Code to provide for current year inclusion of net CFC tested income and removes tax breaks for outsourcing. It repeals the reduced tax rate on global intangible low-taxed income (GILTI), mandates a country-by-country application of foreign tax credit limitations, and limits interest deductions for members of international financial reporting groups. Additionally, the bill treats foreign corporations managed and controlled in the United States as domestic corporations.
Key points
Repeals the reduced tax rate on global intangible low-taxed income (GILTI) and mandates current year inclusion of such income.
Requires foreign tax credit limitations to be applied separately with respect to each country.
Strengthens rules regarding corporate inversions and limits interest deductions for domestic corporations in international financial reporting groups.
Treats foreign corporations managed and controlled primarily within the United States as domestic corporations for income tax purposes.
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Additional Information
Print number: 117_HR_1785
Sponsor: Rep. Doggett, Lloyd [D-TX-35]
Process start date: 2021-03-11