Ending Tax Breaks for Outsourcing: Stricter Rules on Foreign Corporate Income
This Act aims to eliminate tax incentives that encourage large corporations to shift operations and profits outside the United States. It introduces stricter rules for taxing foreign income, requires country-by-country accounting for foreign taxes, and significantly tightens regulations against corporate inversions. The overall goal is to increase US tax revenue and discourage outsourcing.
Key points
Replaces GILTI provisions with 'net CFC tested income' and repeals associated deductions, ensuring foreign profits are taxed at the full US corporate rate.
Mandates country-by-country application of foreign tax credits, preventing companies from using tax credits from high-tax countries to offset US tax on low-tax foreign income.
Tightens rules on corporate inversions, treating foreign corporations as domestic if management and control are primarily located in the US.
Limits interest deductions for US corporations belonging to large international financial groups based on their share of the group's EBITDA.
Status:
Introduced
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