S. 2459

No Tax Breaks for Outsourcing Act

This bill amends the Internal Revenue Code, with respect to the taxation of the foreign-source income of domestic corporations, to:

• eliminate an exemption for certain returns from tangible investments made overseas,
• eliminate deductions for a domestic corporation's foreign-derived intangible income and global intangible low-taxed income,
• repeal a provision that excludes foreign oil and gas extraction income from the tested income of a controlled foreign corporation,
• limit the tax deduction for the interest expenses of a U.S. corporation that is a member of a financial reporting group (i.e., a group that prepares consolidated financial statements according to generally accepted accounting principles or international financial reporting standards),
• modify the rules for the taxation of inverted corporations (U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States), and
• treat certain foreign corporations managed and controlled primarily in the United States as domestic corporations for tax purposes.