This bill, known as the "No Tax Breaks for Outsourcing Act," significantly revises several provisions of the Internal Revenue Code of 1986 to address tax avoidance by multinational corporations. A primary focus is on the taxation of foreign income, particularly by modifying rules related to controlled foreign corporations (CFCs) and foreign tax credits. The legislation repeals the 10% deemed return on qualified business asset investment (QBAI) for global intangible low-taxed income (GILTI), effectively requiring current year inclusion of all net CFC tested income . It also eliminates the deduction for GILTI and foreign-derived intangible income (FDII), thereby increasing the effective tax rate on these earnings. To partially offset this, the bill removes the 80% limitation on the foreign tax credit for net CFC tested income, allowing a 100% credit. A crucial change is the introduction of a country-by-country application for both net CFC tested income calculations and the foreign tax credit limitation. This means income and taxes will be computed separately for each country where a CFC taxable unit operates, preventing companies from averaging high-tax and low-tax foreign income to reduce their U.S. tax liability. The bill also eliminates the ability to carry back foreign tax credits, allowing only carryforwards. Furthermore, the bill tightens rules around interest deductions for multinational groups. It limits the deduction of interest by domestic corporations that are members of an international financial reporting group , capping it based on the corporation's allocable share of the group's reported net interest expense. Any disallowed interest can be carried forward for up to five years. The legislation also strengthens anti-inversion provisions, broadening the definition of an "inverted corporation" that is treated as domestic for tax purposes. This includes cases where more than 50% of the foreign entity's stock is held by former domestic shareholders or partners, or where the management and control of the expanded affiliated group are primarily in the U.S. with significant domestic business activities. These anti-inversion changes are largely retroactive to December 22, 2017. Finally, the bill introduces a new rule treating certain foreign corporations as domestic for income tax purposes if their management and control occur primarily within the United States. This applies to corporations with publicly traded stock or aggregate gross assets of $50 million or more. The effective dates for most provisions are for taxable years beginning after December 31, 2024, with some exceptions.