S409-119

In Committee

No Tax Breaks for Outsourcing Act

119th Congress Introduced Feb 5, 2025

Analysis under review: This bill has generated analysis that may be too generic or incomplete. Clause-level evidence remains available below.

Summary

The No Tax Breaks for Outsourcing Act restructures US international corporate taxation to eliminate incentives for offshore profit shifting and job outsourcing. Section 2 replaces the current GILTI (Global Intangible Low-Taxed Income) regime with a country-by-country 'net CFC tested income' system, preventing companies from blending income from high-tax and low-tax countries to reduce their US tax burden. Section 3 applies foreign tax credit limitations on a per-country basis using taxable units, preventing cross-crediting of taxes paid in different jurisdictions. Section 4 limits interest deductions for US corporations in international financial reporting groups (over M revenue) to their proportional share of the group's net interest expense at 110%. Section 5 expands anti-inversion rules: foreign corporations are treated as domestic if they acquire a US company and former shareholders hold over 50% of the resulting entity, or if management and control remain primarily in the US (currently 80% for full recharacterization). Section 6 treats any foreign corporation whose management and control occurs primarily within the US as a domestic corporation for tax purposes, targeting publicly traded companies and those with M+ in assets.

Evidence Chain:

This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers.

At a Glance

What This Bill Does

Close international tax loopholes that incentivize corporations to shift profits and jobs overseas by reforming GILTI taxation, implementing country-by-country foreign tax credit limits, restricting interest deductions for multinationals, tightening anti-inversion rules, and treating foreign corporations managed from the US as domestic corporations.

Who Benefits

  • US Treasury (increased corporate tax revenue)
  • Domestic-only businesses competing against multinationals
  • US workers in industries where outsourcing is tax-motivated

Who Bears Costs

  • Multinational corporations with significant offshore operations
  • Companies using corporate inversions
  • Foreign-incorporated companies managed from the US

Key Policy Areas

{'domain': 'Tax Policy', 'evidence': ['2', '3', '4', '5', '6']}, {'domain': 'International Trade', 'evidence': ['2', '3', '5', '6']}

Primary Purpose

Close international tax loopholes that incentivize corporations to shift profits and jobs overseas by reforming GILTI taxation, implementing country-by-country foreign tax credit limits, restricting interest deductions for multinationals, tightening anti-inversion rules, and treating foreign corporations managed from the US as domestic corporations.

Policy Domains

{'domain': 'Tax Policy', 'evidence': ['2', '3', '4', '5', '6']} {'domain': 'International Trade', 'evidence': ['2', '3', '5', '6']}

Legislative Strategy

"Systematically close every major mechanism for offshore profit shifting (income blending, cross-crediting, excessive interest deductions, corporate inversions, management-and-control arbitrage) to create a level playing field between domestic and international operations."

Legislative Progress

In Committee
Introduced Committee Passed
Feb 5, 2025

Mr. Whitehouse (for himself, Mr. Durbin, Mr. Murphy, Mr. Reed, …

Feb 5, 2025

Read twice and referred to the Committee on Finance.

Feb 5, 2025

Introduced in Senate

Stakeholder Effects

cui bono?

How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.

Large Corporations
6 mentions across 5 clauses
-6 negative

Companies using or planning corporate inversions, Foreign-incorporated companies with US-based management, Multinational corporations using cross-crediting strategies

Government
3 mentions across 3 clauses
+3 positive

US Treasury

Financial Services
3 mentions across 3 clauses
-3 negative

Financial institutions with cross-border lending structures, Offshore holding companies managing US operations, Tax haven jurisdictions

Professional Services
1 mention across 1 clause
+1 positive

International tax advisory firms

Business Community
1 mention across 1 clause
+1 positive

Domestic-only businesses

Labor
1 mention across 1 clause
+1 positive

US workers in industries prone to inversion-driven outsourcing

6/6
sections analyzed
Full impact breakdown

Bill Structure & Actor Mappings

Who is "The Secretary" in each section?

Domains
Tax Policy
Actor Mappings
"the_secretary"
→ Secretary of the Treasury
Domains
Tax Policy
Actor Mappings
"the_secretary"
→ Secretary of the Treasury
Domains
Tax Policy
Actor Mappings
"the_secretary"
→ Secretary of the Treasury
Domains
Tax Policy International Trade
Domains
Tax Policy
Actor Mappings
"the_secretary"
→ Secretary of the Treasury

Key Definitions

Terms defined in this bill

2 terms
"international financial reporting group" §4(n)(2)

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

"taxable unit" §3(e)(2)(B)

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