This bill significantly modifies the Internal Revenue Code to combat corporate tax inversions, aiming to prevent companies from reincorporating abroad to reduce U.S. tax obligations while maintaining substantial operations and control within the United States. The legislation expands the circumstances under which a foreign corporation will be treated as a domestic corporation for U.S. tax purposes. The bill introduces a new category, an "inverted domestic corporation," which applies to foreign entities that acquire a U.S. company after May 8, 2014. Such an entity will be deemed domestic if more than 50 percent of its stock is held by former U.S. shareholders, or if its management and control are primarily within the United States and it has significant domestic business activities. This new definition significantly broadens the scope of what constitutes an inversion. Additionally, the bill modifies the existing framework by treating a foreign corporation as domestic if it would meet the criteria for a "surrogate foreign corporation" with an 80 percent ownership threshold by former U.S. shareholders. The legislation defines "significant domestic business activities" based on factors such as the percentage of employees, compensation, assets, or income located or derived in the U.S., generally set at 25 percent. An exception exists if the expanded affiliated group has substantial business activities in the foreign country of organization. These amendments apply retroactively to taxable years ending after May 8, 2014.