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S 409119th CongressIntroduced
No Tax Breaks for Outsourcing Act
Introduced: Oct 28, 2025
Standard Summary
Comprehensive overview in 1-2 paragraphs
The No Tax Breaks for Outsourcing Act (S.409) amends the Internal Revenue Code to include net CFC‑tested income in current‑year inclusion, apply country‑by‑country limitations, restrict interest deductions for domestic corporations in international financial reporting groups, modify inverted corporation rules, and eliminate the carryback of foreign tax credits. The changes take effect for taxable years beginning after 2024.
Key Points
- 1Net CFC‑tested income is now included in current‑year inclusion.
- 2Country‑by‑country application of limitations on foreign tax credits.
- 3Limitations on interest deductions for domestic corporations in international financial reporting groups.
- 4Elimination of carryback of foreign tax credits.
Impact Areas
Multinational corporations and U.S. shareholdersTax professionals and accountantsForeign‑controlled corporationsU.S. tax policy and compliance
Generated by openai/gpt-oss-20b:free on Nov 19, 2025