This legislation significantly modifies the rules relating to inverted corporations under the Internal Revenue Code, aiming to prevent companies from reincorporating abroad to reduce their U.S. tax liability. It expands the criteria under which a foreign corporation is treated as a domestic corporation for tax purposes, thereby subjecting it to U.S. taxation on its worldwide income. This applies if, following an acquisition of a U.S. company after May 8, 2014, either more than 50 percent of the foreign entity's stock is held by former U.S. shareholders or partners, or its management and control are primarily within the United States alongside significant domestic business activities. The bill defines an entity as having significant domestic business activities if at least 25 percent of its employees, employee compensation, assets, or income are located or derived in the United States. Furthermore, management and control are considered primarily in the U.S. if substantially all executive officers and senior management responsible for day-to-day decisions are based there. An exception exists if the expanded affiliated group demonstrates substantial business activities in the foreign country where it is organized. These amendments are effective for taxable years ending after May 8, 2014.