No Tax Breaks for Outsourcing Act
Analysis under review: This bill has generated analysis that may be too generic or incomplete. Clause-level evidence remains available below.
Summary
What This Bill Does
The bill defines eliminates the GILTI high-tax exclusion and Section 250 deduction, requires full current-year inclusion of all controlled foreign corporation tested income on a country-by-country basis, removes foreign tax, defines applies foreign tax credit limitation on a country-by-country basis using taxable units, preventing cross-crediting between high-tax and low-tax jurisdictions, and limits interest deductions for domestic corporations that are members of international financial reporting groups with over million in average annual gross receipts, capping deductions based on EBITDA-allocated share. It relies on definition changes, regulation, tax increase, and repeal. The main policy areas are Taxation, Finance, Energy, and Healthcare.
Who Benefits and How
U.S. Treasury could gain revenue opportunities and Domestic-only companies would be affected.
Who Bears the Burden and How
U.S. multinational corporations with controlled foreign corporations could face higher costs, Foreign-incorporated companies managed from the U.S. with M+ in assets could face higher costs, and Domestic subsidiaries of large multinational corporate groups could face higher costs.
Key Provisions
- Defines eliminates the GILTI high-tax exclusion and Section 250 deduction, requires full current-year inclusion of all controlled foreign corporation tested income on a country-by-country basis, removes foreign tax...
- Defines applies foreign tax credit limitation on a country-by-country basis using taxable units, preventing cross-crediting between high-tax and low-tax jurisdictions.
- Limits interest deductions for domestic corporations that are members of international financial reporting groups with over million in average annual gross receipts, capping deductions based on EBITDA-allocated share...
- Expands anti-inversion rules to treat more foreign corporations as domestic, including entities where more than 50% of stock is held by former U.S.
- Defines treats foreign-incorporated corporations that are managed and controlled primarily within the United States as domestic corporations for income tax purposes, targeting publicly traded companies or those...
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 defines eliminates the GILTI high-tax exclusion and Section 250 deduction, requires full current-year inclusion of all controlled foreign corporation tested income on a country-by-country basis, removes foreign tax, defines applies foreign tax credit limitation on a country-by-country basis using taxable units, preventing cross-crediting between high-tax and low-tax jurisdictions, and limits interest deductions for domestic corporations that are members of international financial reporting groups with over million in average annual gross receipts, capping deductions based on EBITDA-allocated share.
Key Policy Areas
Taxation, Finance, Energy, Healthcare
Primary Purpose
The bill defines eliminates the GILTI high-tax exclusion and Section 250 deduction, requires full current-year inclusion of all controlled foreign corporation tested income on a country-by-country basis, removes foreign tax, defines applies foreign tax credit limitation on a country-by-country basis using taxable units, preventing cross-crediting between high-tax and low-tax jurisdictions, and limits interest deductions for domestic corporations that are members of international financial reporting groups with over million in average annual gross receipts, capping deductions based on EBITDA-allocated share.
Policy Domains
No Tax Breaks for Outsourcing Act
Identified Gains
- U.S. Treasury
- Domestic-only companies
Identified Costs
- U.S. multinational corporations with controlled foreign corporations
- Foreign-incorporated companies managed from the U.S. with M+ in assets
- Domestic subsidiaries of large multinational corporate groups
- Corporations that have completed or are planning corporate inversions
- Companies using earnings stripping through intercompany debt
Sponsors
Legislative Progress
In CommitteeMr. Doggett (for himself, Ms. Adams, Ms. Ansari, Ms. Balint, …
Referred to the House Committee on Ways and Means.
Introduced in House
Stakeholder Effects
cui bono?How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.
Corporations that have completed or are planning corporate inversions, Domestic subsidiaries of large multinational corporate groups, Foreign-incorporated companies managed from the U.S. with M+ in assets
Foreign-incorporated investment management firms run from the U.S., International financial groups with U.S. operations (>M revenue)
Companies considering future inversions for tax purposes, Companies using earnings stripping through intercompany debt
Oil and gas companies with foreign extraction subsidiaries
Technology companies using offshore IP holding structures
Pharmaceutical companies with foreign manufacturing subsidiaries
Companies using cross-crediting strategies between high-tax and low-tax countries
Bill Structure & Actor Mappings
Who is "The Secretary" in each section?
- "the_secretary"
- → Secretary of the Treasury (IRS)
Key Definitions
Terms defined in this bill
Replaces global intangible low-taxed income (GILTI). The net tested income of controlled foreign corporations attributable to U.S. shareholders, now calculated on a country-by-country basis using CFC taxable units.
For foreign tax credit purposes: the taxpayer itself, each foreign corporation where taxpayer is a U.S. shareholder, pass-through entity interests in different countries, and branches giving rise to taxable presence in other countries.
A group of entities that includes at least one foreign corporation in U.S. trade/business or at least one domestic and one foreign corporation, prepares consolidated financial statements, and reports average annual gross receipts over $100,000,000 for the 3-year period.
A foreign corporation that acquires substantially all properties of a domestic corporation/partnership where more than 50% of stock is held by former domestic shareholders, or where management/control is primarily in the U.S. with significant domestic business activities.
A foreign corporation with stock traded on established markets or $50M+ in gross assets, whose management and control occurs primarily within the United States. Treated as domestic for income tax purposes.
Any taxable unit described in section 904(e)(2)(B) clauses (ii)-(iv), determined by substituting controlled foreign corporation for foreign corporation. Used for country-by-country GILTI calculation.
The ratio of a domestic corporation allocable share of the group reported net interest expense to its own reported net interest expense, capped at 100%. Limits interest deductions to the corporation proportional share.
A person or entity subject to tax under the tax law of a country as a resident. Entities organized in countries without income tax are treated as tax residents of that country.
Any partnership or other entity to the extent income, gain, deduction, or loss is taken into account in determining the income or loss of a person owning an interest in such entity.
A taxable presence of a tax resident in a country other than its country of residence as determined under such other country tax law.
Earnings before interest, taxes, depreciation, and amortization as determined in the international financial reporting group consolidated financial statements. Used to allocate net interest expense among group members.
We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.
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