This bill introduces a new 25% excise tax on certain payments made by United States persons to foreign entities for services benefiting U.S. consumers, termed "outsourcing payments." These payments, which include fees, royalties, and service charges made in a trade or business, will also explicitly not be deductible for income tax purposes. The Secretary of the Treasury is authorized to prescribe regulations and guidance to prevent avoidance or abuse of these provisions, including through related parties or transfer pricing arrangements. The legislation also establishes the Domestic Workforce Fund , a trust fund in the U.S. Treasury, to which revenue from this new excise tax and related penalties will be appropriated. Amounts in the fund will be exclusively available for specific purposes without further appropriation. These include workforce development and retraining programs administered by the Department of Labor, apprenticeship programs, and partnerships with industry to expand domestic employment in sectors impacted by outsourcing. Additionally, the fund will provide grants to states for workforce development initiatives targeted at communities with high levels of job displacement. The amendments made by this bill, including the excise tax and the denial of income tax deduction, are set to apply to payments made after December 31, 2025, and include provisions for increased penalties for non-payment and new reporting requirements.
This bill introduces a new 25% excise tax on certain payments made by United States persons to foreign entities for services benefiting U.S. consumers, termed "outsourcing payments." These payments, which include fees, royalties, and service charges made in a trade or business, will also explicitly not be deductible for income tax purposes. The Secretary of the Treasury is authorized to prescribe regulations and guidance to prevent avoidance or abuse of these provisions, including through related parties or transfer pricing arrangements. The legislation also establishes the Domestic Workforce Fund , a trust fund in the U.S. Treasury, to which revenue from this new excise tax and related penalties will be appropriated. Amounts in the fund will be exclusively available for specific purposes without further appropriation. These include workforce development and retraining programs administered by the Department of Labor, apprenticeship programs, and partnerships with industry to expand domestic employment in sectors impacted by outsourcing. Additionally, the fund will provide grants to states for workforce development initiatives targeted at communities with high levels of job displacement. The amendments made by this bill, including the excise tax and the denial of income tax deduction, are set to apply to payments made after December 31, 2025, and include provisions for increased penalties for non-payment and new reporting requirements.