To amend the Internal Revenue Code of 1986 to provide for current year inclusion of net CFC tested income, and for other purposes.
Summary
What This Bill Does
The bill requires short title, etc This Act may be cited as the No Tax Breaks for Outsourcing Act, provides current year inclusion of net CFC tested income Section 951A(a) is amended by striking global intangible low-taxed income and inserting net CFC tested income, and creates country-by-country application of limitation on foreign tax credit based on taxable units Section 904 is amended by inserting after subsection (d) the following new subsection: (e)Country-by-Country application. It relies on compliance mandates, definition changes, tax rate changes, and appropriations. The main policy areas are Homeowners, Finance, Housing, and Environment.
Who Benefits and How
Homeowners, tenants, or housing market participants affected by the bill could face lower compliance burdens, Financial services firms and customers affected by the bill could face lower compliance burdens, and Environmental and public health interests affected by the bill could gain revenue opportunities.
Who Bears the Burden and How
Federal, state, or local agencies responsible for implementing the clause would take on compliance duties, Homeowners, tenants, or housing market participants affected by the bill would take on compliance duties, and Oil and gas producers, refiners, or users affected by the bill would take on compliance duties.
Key Provisions
- Requires short title, etc This Act may be cited as the No Tax Breaks for Outsourcing Act.
- Provides current year inclusion of net CFC tested income Section 951A(a) is amended by striking global intangible low-taxed income and inserting net CFC tested income.
- Creates country-by-country application of limitation on foreign tax credit based on taxable units Section 904 is amended by inserting after subsection (d) the following new subsection: (e)Country-by-Country application...
- Provides limitation on deduction of interest by domestic corporations which are members of an international financial reporting group Section 163 is amended by redesignating subsection (n) as subsection (p) and...
- Requires modifications to rules relating to inverted corporations Subsection (b) of section 7874 is amended to read as follows: (b)Inverted corporations treated as domestic corporations(1)In generalNotwithstanding...
Evidence Chain:
This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.
At a Glance
What This Bill Does
The bill requires short title, etc This Act may be cited as the No Tax Breaks for Outsourcing Act, provides current year inclusion of net CFC tested income Section 951A(a) is amended by striking global intangible low-taxed income and inserting net CFC tested income, and creates country-by-country application of limitation on foreign tax credit based on taxable units Section 904 is amended by inserting after subsection (d) the following new subsection: (e)Country-by-Country application.
Key Policy Areas
Homeowners, Finance, Housing, Environment
Primary Purpose
The bill requires short title, etc This Act may be cited as the No Tax Breaks for Outsourcing Act, provides current year inclusion of net CFC tested income Section 951A(a) is amended by striking global intangible low-taxed income and inserting net CFC tested income, and creates country-by-country application of limitation on foreign tax credit based on taxable units Section 904 is amended by inserting after subsection (d) the following new subsection: (e)Country-by-Country application.
Policy Domains
Whole bill
Identified Gains
- Homeowners, tenants, or housing market participants affected by the bill
- Financial services firms and customers affected by the bill
- Environmental and public health interests affected by the bill
- Businesses and employers affected by the bill
Identified Costs
- Federal, state, or local agencies responsible for implementing the clause
- Homeowners, tenants, or housing market participants affected by the bill
- Oil and gas producers, refiners, or users affected by the bill
- Foreign businesses and cross-border trade participants affected by the bill
- Financial services firms and customers affected by the bill
Sponsors
Legislative Progress
IntroducedMr. Doggett (for himself, Ms. Adams, Ms. Barragán, Mrs. Beatty, …
Impact analysis is available but no clear stakeholder effects identified. View clause-level analysis →
Bill Structure & Actor Mappings
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