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No Tax Breaks for Outsourcing Act

The bill amends the Internal Revenue Code of 1986 to reduce tax avoidance by multinational corporations. It replaces provisions regarding GILTI with "net CFC tested income," requiring current-year inclusion of this income and repealing reduced tax rates. The legislation introduces country-by-country application of foreign tax credit limitations, limits interest deductions for international financial reporting groups, and treats foreign corporations managed and controlled in the US as domestic entities.
Key points
Taxation of Foreign Profits: Replaces "global intangible low-taxed income" (GILTI) with "net CFC tested income" and repeals deductions that provided a reduced tax rate.
Country-by-Country Rule: Requires foreign tax credit limitations and income calculations to be applied separately for each country, preventing the blending of income from tax havens with high-tax jurisdictions.
Interest Deduction Limit: Limits interest deductions for domestic corporations that are members of an international financial reporting group.
Inversions and Management: Treats foreign corporations as domestic corporations if they are managed and controlled primarily in the United States or meet corporate inversion criteria.
article Official text account_balance Process page
Introduced
Citizen Poll
No votes cast
Additional Information
Print number: 119_S_409
Sponsor: Sen. Whitehouse, Sheldon [D-RI]
Process start date: 2025-02-05
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Source data: api.congress.gov
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OFFICIAL LEGAL TITLE

No Tax Breaks for Outsourcing Act

FREQUENTLY ASKED QUESTIONS

What is the official ID of this bill?

The official print number for this legislation is 119_S_409.

Which chamber initiated this legislation?

This legislation was initiated in the Senate.

When did the legislative process begin?

The process officially started on 2025-02-05.

What are the main provisions?

Key points include:

  • Taxation of Foreign Profits: Replaces "global intangible low-taxed income" (GILTI) with "net CFC tested income" and repeals deductions that provided a reduced tax rate.
  • Country-by-Country Rule: Requires foreign tax credit limitations and income calculations to be applied separately for each country, preventing the blending of income from tax havens with high-tax jurisdictions.
  • Interest Deduction Limit: Limits interest deductions for domestic corporations that are members of an international financial reporting group.
  • Inversions and Management: Treats foreign corporations as domestic corporations if they are managed and controlled primarily in the United States or meet corporate inversion criteria.
What is the specific legal status?

The current status is Introduced.

Where can I read the full text of this legislation?

The full official text is available at: View full text

Who is the primary sponsor?

The primary sponsor is Sen. Whitehouse, Sheldon [D-RI].

What is the latest detailed status?

The latest detailed status is: Introduced in Senate

Is this summary verified?

Yes. This content was analyzed by AI and verified by the Lustra Judge System on 2025-12-31.

CATEGORIES

Taxes Economy