S.409

No Tax Breaks for Outsourcing Act limits interest deductions and foreign tax credits for corporations with significant U.S.

The No Tax Breaks for Outsourcing Act amends the Internal Revenue Code to limit interest deductions and foreign tax credits for corporations that manage and control their operations primarily in the U.S. but have significant business activities in foreign countries. It introduces a country-by-country application of tax rules based on taxable units, affecting domestic corporations in international financial reporting groups. The bill also modifies rules for inverted corporations and treats certain foreign corporations managed and controlled in the U.S. as domestic corporations.