Bill > S357

This bill, the "No Tax Breaks for Outsourcing Act", proposes several key changes to the Internal Revenue Code: 1. It repeals the provision for global intangible low-taxed income (GILTI) and instead includes current-year "net CFC tested income" of controlled foreign corporations (CFCs) in the income of U.S. shareholders. It also requires a country-by-country application of this provision based on the CFC taxable units. 2. It eliminates the reduced tax rate on GILTI and foreign-derived intangible income (FDII), and increases the deemed paid foreign tax credit for taxes properly attributable to tested income. 3. It repeals the high-tax exception for foreign base company income and insurance income, and treats foreign base company oil-related income as subpart F income. 4. It limits the deduction of interest by domestic corporations that are members of an international financial reporting group, based on the group's net interest expense. 5. It modifies the rules relating to "inverted" corporations, expanding the circumstances under which a foreign corporation is treated as a domestic corporation for tax purposes. 6. It treats certain foreign corporations that are managed and controlled primarily in the United States as domestic corporations for income tax purposes. The bill aims to eliminate tax incentives for U.S. companies to shift profits and operations overseas, and to ensure that foreign-source income is appropriately taxed.