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 creates replaces GILTI with country-by-country net CFC tested income, eliminating income blending across jurisdictions that allowed high-tax countries to offset low-tax havens, creates applies foreign tax credit limitation on a per-country basis using taxable units, preventing cross-crediting of taxes paid in different jurisdictions, and limits interest deductions for US corporations in international groups (over M revenue) to 110% of their proportional share of group net interest expense. It relies on tax rate changes, tax deductions, compliance mandates, and definition changes. The main policy areas are Finance and Labor.
Who Benefits and How
US Treasury could gain revenue opportunities, US workers in industries prone to inversion-driven outsourcing could face reduced risk, and International tax advisory firms could gain revenue opportunities.
Who Bears the Burden and How
Multinational corporations with offshore subsidiaries could face higher costs, Foreign-incorporated companies with US-based management could face higher costs, and Companies using or planning corporate inversions could face higher barriers.
Key Provisions
- Creates replaces GILTI with country-by-country net CFC tested income, eliminating income blending across jurisdictions that allowed high-tax countries to offset low-tax havens.
- Creates applies foreign tax credit limitation on a per-country basis using taxable units, preventing cross-crediting of taxes paid in different jurisdictions.
- Limits interest deductions for US corporations in international groups (over M revenue) to 110% of their proportional share of group net interest expense.
- Expands anti-inversion rules to treat foreign corporations as domestic when former US shareholders hold over 50% (down from 60%) or when management and control remain primarily in the US with significant domestic...
- Defines treats foreign-incorporated corporations managed and controlled primarily from the US as domestic corporations for tax purposes, targeting publicly traded companies and those with M+ assets.
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 creates replaces GILTI with country-by-country net CFC tested income, eliminating income blending across jurisdictions that allowed high-tax countries to offset low-tax havens, creates applies foreign tax credit limitation on a per-country basis using taxable units, preventing cross-crediting of taxes paid in different jurisdictions, and limits interest deductions for US corporations in international groups (over M revenue) to 110% of their proportional share of group net interest expense.
Key Policy Areas
Finance, Labor
Primary Purpose
The bill creates replaces GILTI with country-by-country net CFC tested income, eliminating income blending across jurisdictions that allowed high-tax countries to offset low-tax havens, creates applies foreign tax credit limitation on a per-country basis using taxable units, preventing cross-crediting of taxes paid in different jurisdictions, and limits interest deductions for US corporations in international groups (over M revenue) to 110% of their proportional share of group net interest expense.
Policy Domains
Section 2 - Net CFC Tested Income (GILTI Reform)
Identified Gains
- US Treasury
- US workers in industries prone to inversion-driven outsourcing
- International tax advisory firms
- Domestic-only businesses
Identified Costs
- Multinational corporations with offshore subsidiaries
- Foreign-incorporated companies with US-based management
- Companies using or planning corporate inversions
- US subsidiaries of multinational groups with excess interest deductions
- Multinational corporations using cross-crediting strategies
Sponsors
Legislative Progress
In CommitteeMr. Whitehouse (for himself, Mr. Durbin, Mr. Murphy, Mr. Reed, …
Read twice and referred to the Committee on Finance.
Introduced in Senate
Stakeholder Effects
cui bono?How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.
Companies using or planning corporate inversions, Foreign-incorporated companies with US-based management, Multinational corporations using cross-crediting strategies
Financial institutions with cross-border lending structures, Offshore holding companies managing US operations, Tax haven jurisdictions
US workers in industries prone to inversion-driven outsourcing
Bill Structure & Actor Mappings
Who is "The Secretary" in each section?
- "the_secretary"
- → Secretary of the Treasury
- "the_secretary"
- → Secretary of the Treasury
- "the_secretary"
- → Secretary of the Treasury
- "the_secretary"
- → Secretary of the Treasury
Key Definitions
Terms defined in this bill
A group of entities with at least one foreign and one domestic corporation (or foreign corp in US trade), preparing consolidated financials, with aggregate gross receipts over M
The taxpayer itself, each CFC, pass-through entity interests in different-country jurisdictions, and branches giving rise to taxable presence in another country
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.
Learn more about our methodology