S.Amdt. 4412

This amendment, titled the "No Tax Breaks for Outsourcing Act," aims to modify the Internal Revenue Code of 1986 to change how certain foreign corporations and international financial groups are taxed.

The amendment seeks to add or change the following:

• Taxing Foreign Income: It changes the rules for "net CFC tested income" by applying them on a country-by-country basis and repealing the reduced rate of tax on that income and foreign-derived intangible income.
• Foreign Tax Credits: It implements a country-by-country application for foreign tax credit limitations based on "taxable units" and eliminates the ability to carry back these credits.
• Interest Deductions: It limits the amount of interest domestic corporations can deduct if they are part of an international financial reporting group.
• Corporate Inversions: It modifies rules for "inverted corporations," treating certain foreign corporations as domestic corporations if they meet specific ownership, management, or business activity thresholds.
• Management and Control: It establishes that foreign corporations managed and controlled primarily within the United States will be treated as domestic corporations for income tax purposes, provided they are traded on an established securities market or have aggregate gross assets of $50 million or more.