No Tax Breaks for Outsourcing Act This bill amends the Internal Revenue Code, with respect to the taxation of the foreign-source income of domestic corporations, to: eliminate an exemption for certain returns from tangible investments made overseas, eliminate deductions for a domestic corporation's foreign-derived intangible income and global intangible low-taxed income, repeal a provision that excludes foreign oil and gas extraction income from the tested income of a controlled foreign corporation, limit the tax deduction for the interest expenses of a U.S. corporation that is a member of a financial reporting group (i.e., a group that prepares consolidated financial statements according to generally accepted accounting principles or international financial reporting standards), modify the rules for the taxation of inverted corporations (U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States), and treat certain foreign corporations managed and controlled primarily in the United States as domestic corporations for tax purposes.
Accounting and auditingCorporate finance and managementForeign and international corporationsIncome tax deductionsInterest, dividends, interest ratesOil and gasTax administration and collection, taxpayersTaxation of foreign incomeU.S. and foreign investments
A bill to amend the Internal Revenue Code of 1986 to provide for current year inclusion of net CFC tested income, and for other purposes.
USA115th CongressS-2459| Senate
| Updated: 2/27/2018
No Tax Breaks for Outsourcing Act This bill amends the Internal Revenue Code, with respect to the taxation of the foreign-source income of domestic corporations, to: eliminate an exemption for certain returns from tangible investments made overseas, eliminate deductions for a domestic corporation's foreign-derived intangible income and global intangible low-taxed income, repeal a provision that excludes foreign oil and gas extraction income from the tested income of a controlled foreign corporation, limit the tax deduction for the interest expenses of a U.S. corporation that is a member of a financial reporting group (i.e., a group that prepares consolidated financial statements according to generally accepted accounting principles or international financial reporting standards), modify the rules for the taxation of inverted corporations (U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States), and treat certain foreign corporations managed and controlled primarily in the United States as domestic corporations for tax purposes.
Accounting and auditingCorporate finance and managementForeign and international corporationsIncome tax deductionsInterest, dividends, interest ratesOil and gasTax administration and collection, taxpayersTaxation of foreign incomeU.S. and foreign investments