No Tax Breaks for Outsourcing Act

Redefining Net CFC Tested Income: The bill repeals the tax-free deemed return on investments by striking "global intangible low-taxed income" and replacing it with "net CFC tested income" (Section 2(a)).

Country-by-Country Tax Application: The bill implements a system where net CFC tested income and other items are determined separately for each country where a taxable unit is a resident or located (Section 2(b)).

Enhanced Regulatory Authority: The Secretary is granted authority to issue regulations to prevent the avoidance of the purposes of the section, including adjustments to basis and tax attributes (Section 2(c)).

Addressing Inverted Corporations: The bill modifies rules so that foreign corporations are treated as domestic if they acquire substantially all assets of a domestic corporation or partnership and have management and control occurring primarily within the United States (Section 5(a)).

Limitations on Interest Deductions: Domestic corporations that are members of an international financial reporting group will face limits on their deductions for interest paid or accrued (Section 4(a)).

Restrictions on Inverted Corporations: The bill expands the definition of an "inverted domestic corporation," treating more foreign corporations as domestic if their management and control occurs primarily within the United States (Section 5(a)).

Treatment of Managed Foreign Corporations: Certain foreign corporations that are regularly traded or have significant assets, and are managed and controlled primarily within the United States, will be treated as domestic corporations for income tax purposes (Section 6(a)).