To amend the Internal Revenue Code of 1986 to deny deduction for outsourcing payments.

This legislative proposal seeks to amend the Internal Revenue Code of 1986 by denying income tax deductions for specific "outsourcing payments." The primary goal is to disincentivize companies from moving jobs or services abroad by removing a current tax advantage associated with such activities. An "outsourcing payment" is broadly defined as any premium, fee, royalty, or service charge made in the course of a trade or business to a foreign person for labor or services whose benefits are directed, directly or indirectly, to consumers located within the United States. The bill specifies that a "foreign person" is anyone not a U.S. person, excluding entities organized under U.S. possession laws. For payments covering services directed to consumers both inside and outside the U.S., only the portion attributable to U.S. consumers will be considered an outsourcing payment. The Secretary of the Treasury is authorized to issue regulations to prevent avoidance or abuse of these provisions, including through transfer pricing arrangements. These amendments are slated to apply to payments made after December 31, 2025.