HR 995119th CongressIn Committee

No Tax Breaks for Outsourcing Act

Introduced: Feb 5, 2025

Sponsor: Rep. Doggett, Lloyd [D-TX-37] (D-Texas)

Standard Summary

Comprehensive overview in 1-2 paragraphs

H.R. 995 amends the Internal Revenue Code to include net CFC‑tested income in the current‑year inclusion, imposes country‑by‑country limitations on foreign tax credits, restricts interest deductions for domestic corporations in international financial reporting groups, and reclassifies certain foreign corporations as domestic.

Key Points

1Replaces “global intangible low‑taxed income” with “net CFC‑tested income” for current‑year inclusion.
2Adds a country‑by‑country application of the foreign tax credit based on CFC taxable units.
3Limits interest deductions for domestic corporations that are members of international financial reporting groups.
4Modifies rules for inverted corporations and treats foreign corporations managed in the U.S. as domestic.
5Provides regulatory authority and effective dates for all amendments.

Impact Areas

Multinational corporations and their U.S. subsidiariesDomestic corporations in international financial reporting groupsShareholders of CFCsIRS and federal tax enforcement agencies

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