Bill > S561

This bill, titled the "Offshoring Prevention Act," amends the Internal Revenue Code of 1986 to ensure that income earned by controlled foreign corporations (CFCs) from "imported property income" is taxed in the United States. Imported property income is defined as income derived from manufacturing, producing, growing, extracting, selling, exchanging, disposing of, leasing, renting, or licensing property that is imported into the United States by the CFC or a related person, or property that was reasonably expected to be imported into the United States when sold to an unrelated person. The bill provides exceptions for certain exported property and agricultural commodities not grown in the U.S. in commercially marketable quantities. It also clarifies that the definition of "United States" for these purposes includes U.S. territories. Furthermore, the bill establishes separate limitations for foreign tax credits related to this imported property income and makes conforming amendments to various sections of the tax code. These changes are intended to prevent companies from shifting profits to foreign subsidiaries by treating income derived from property imported into the U.S. as foreign-source income, thereby avoiding U.S. taxation.