A bill to amend the Internal Revenue Code of 1986 to modify the global intangible low-taxed income by repealing the tax-free deemed return on investments and determining net CFC tested income on a per-country basis.
Removing Incentives for Outsourcing Act This bill modifies the tax treatment of foreign source income of domestic corporations to: (1) eliminate a provision that allows companies to deduct a portion of the tangible assets of their controlled foreign corporations (CFCs) before the tax on foreign income applies, and (2) require net CFC tested income to be determined on a country-by-country basis rather than globally. The bill also requires the Joint Committee on Taxation to study options for reforming laws related to the taxation of income from international sources.
Congressional oversightForeign and international corporationsIncome tax deductionsTax administration and collection, taxpayersTaxation of foreign income
A bill to amend the Internal Revenue Code of 1986 to modify the global intangible low-taxed income by repealing the tax-free deemed return on investments and determining net CFC tested income on a per-country basis.
USA115th CongressS-3674| Senate
| Updated: 11/28/2018
Removing Incentives for Outsourcing Act This bill modifies the tax treatment of foreign source income of domestic corporations to: (1) eliminate a provision that allows companies to deduct a portion of the tangible assets of their controlled foreign corporations (CFCs) before the tax on foreign income applies, and (2) require net CFC tested income to be determined on a country-by-country basis rather than globally. The bill also requires the Joint Committee on Taxation to study options for reforming laws related to the taxation of income from international sources.
Congressional oversightForeign and international corporationsIncome tax deductionsTax administration and collection, taxpayersTaxation of foreign income