No Tax Breaks for Outsourcing Act
Sponsored By: Representative Doggett
Introduced
Summary
Overhauls how the U.S. taxes multinational profits by replacing GILTI with a country-by-country framework. The bill would also repeal the FDII reduced-rate break and tighten cross-border rules on interest, inversions, and foreign tax credits.
Show full summary
- U.S. shareholders of foreign groups: Would replace GILTI with a new "net CFC tested income" measured country-by-country, narrow exclusions, treat oil-related foreign income as Subpart F, and increase the deemed-paid foreign tax credit to 100% for tested income. Many changes would apply to taxable years beginning after December 31, 2024.
- Domestic corporations in international financial reporting groups: Would limit interest deductions by allocating group net interest based on EBITDA and would allow disallowed interest to carry forward for up to five years.
- Inversions and foreign firms managed in the U.S.: Would tighten inversion rules by raising the surrogate-foreign ownership threshold to 80% and creating an "inverted domestic corporation" test, and would allow some foreign corporations managed and controlled in the U.S. to be treated as domestic after two years.
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Bill Overview
Analyzed Economic Effects
7 provisions identified: 1 benefits, 5 costs, 1 mixed.
Full credit for foreign taxes
This bill would let U.S. shareholders claim a deemed-paid foreign tax credit equal to 100% of properly attributable foreign taxes on tested income. It would remove the prior 80% cap. The change would apply to tax years starting after December 31, 2024.
End low tax rate for FDII
This bill would repeal the reduced-rate rule for foreign-derived intangible income (FDII). Domestic corporations that used the lower rate would face higher U.S. tax. The change would apply to taxable years beginning after December 31, 2024.
Foreign tax credits limited by country
This bill would require taxpayers to compute the foreign tax credit limit separately for each country. Branches and U.S. possessions would count as separate countries. It would also remove the ability to carry foreign tax credits back to the prior year. The changes would apply to tax years starting after December 31, 2024.
Higher U.S. tax on offshore profits
This bill would rename GILTI to "net CFC tested income" and narrow what counts as tested income. U.S. shareholders would compute that income by country. It would add certain oil-related foreign income to Subpart F and remove the high-tax exclusion. These rules would apply to foreign corporations' tax years starting after December 31, 2024.
New limits and carryforwards for interest
This bill would limit interest deductions for members of large international financial reporting groups using an EBITDA-based share test. It would also let disallowed interest be carried forward and treated as paid interest for up to five years. The rules would apply to tax years starting after December 31, 2024.
Tighter rules on corporate inversions
This bill would tighten inversion rules by raising the ownership test to 80% and adding a domestic business activity test. It would also let the IRS assess tax tied to those changes for up to three years after enactment. The changes apply to taxable years ending after December 22, 2017.
Treat U.S.-managed foreign firms as domestic
This bill would treat some foreign corporations managed and controlled mainly in the United States as domestic for tax purposes. It would apply when the firm's stock trades regularly or its assets (including assets under management) are $50,000,000 or more. The rule would start two years after enactment and allow limited waivers.
Sponsors & CoSponsors
Sponsor
Doggett
TX • D
Cosponsors
Adams
NC • D
Sponsored 2/5/2025
Ansari
AZ • D
Sponsored 2/5/2025
Balint
VT • D
Sponsored 2/5/2025
Barragan
CA • D
Sponsored 2/5/2025
Beatty
OH • D
Sponsored 2/5/2025
Bishop
GA • D
Sponsored 2/5/2025
Bonamici
OR • D
Sponsored 2/5/2025
Boyle (PA)
PA • D
Sponsored 2/5/2025
Brown
OH • D
Sponsored 2/5/2025
Brownley
CA • D
Sponsored 2/5/2025
Budzinski
IL • D
Sponsored 2/5/2025
Carson
IN • D
Sponsored 2/5/2025
Carter (LA)
LA • D
Sponsored 2/5/2025
Casar
TX • D
Sponsored 2/5/2025
Case
HI • D
Sponsored 2/5/2025
Chu
CA • D
Sponsored 2/5/2025
Clarke (NY)
NY • D
Sponsored 2/5/2025
Cleaver
MO • D
Sponsored 2/5/2025
Cohen
TN • D
Sponsored 2/5/2025
Conaway
NJ • D
Sponsored 2/5/2025
Crockett
TX • D
Sponsored 2/5/2025
Crow
CO • D
Sponsored 2/5/2025
Davis (IL)
IL • D
Sponsored 2/5/2025
Davis (NC)
NC • D
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Dean (PA)
PA • D
Sponsored 2/5/2025
McClain Delaney
MD • D
Sponsored 2/5/2025
DeLauro
CT • D
Sponsored 2/5/2025
DelBene
WA • D
Sponsored 2/5/2025
Deluzio
PA • D
Sponsored 2/5/2025
DeSaulnier
CA • D
Sponsored 2/5/2025
Dexter
OR • D
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Dingell
MI • D
Sponsored 2/5/2025
Escobar
TX • D
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Espaillat
NY • D
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Evans (PA)
PA • D
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Leger Fernandez
NM • D
Sponsored 2/5/2025
Foster
IL • D
Sponsored 2/5/2025
Foushee
NC • D
Sponsored 2/5/2025
Frankel, Lois
FL • D
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Frost
FL • D
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Garamendi
CA • D
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Garcia (IL)
IL • D
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Garcia (CA)
CA • D
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Garcia (TX)
TX • D
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Golden (ME)
ME • D
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Goldman (NY)
NY • D
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Gomez
CA • D
Sponsored 2/5/2025
Green, Al (TX)
TX • D
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Grijalva
AZ • D
Sponsored 2/5/2025
Hayes
CT • D
Sponsored 2/5/2025
Horsford
NV • D
Sponsored 2/5/2025
Hoyle (OR)
OR • D
Sponsored 2/5/2025
Huffman
CA • D
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Ivey
MD • D
Sponsored 2/5/2025
Jackson (IL)
IL • D
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Jayapal
WA • D
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Johnson (GA)
GA • D
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Kaptur
OH • D
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Kelly (IL)
IL • D
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Kennedy (NY)
NY • D
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Khanna
CA • D
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Landsman
OH • D
Sponsored 2/5/2025
Larson (CT)
CT • D
Sponsored 2/5/2025
Lee (PA)
PA • D
Sponsored 2/5/2025
Lieu
CA • D
Sponsored 2/5/2025
Lynch
MA • D
Sponsored 2/5/2025
Magaziner
RI • D
Sponsored 2/5/2025
McBath
GA • D
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McBride
DE • D
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McCollum
MN • D
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McGarvey
KY • D
Sponsored 2/5/2025
McGovern
MA • D
Sponsored 2/5/2025
Meeks
NY • D
Sponsored 2/5/2025
Menendez
NJ • D
Sponsored 2/5/2025
Meng
NY • D
Sponsored 2/5/2025
Mfume
MD • D
Sponsored 2/5/2025
Moulton
MA • D
Sponsored 2/5/2025
Mrvan
IN • D
Sponsored 2/5/2025
Nadler
NY • D
Sponsored 2/5/2025
Neguse
CO • D
Sponsored 2/5/2025
Norcross
NJ • D
Sponsored 2/5/2025
Del. Norton, Eleanor Holmes [D-DC-At Large]
DC • D
Sponsored 2/5/2025
Ocasio-Cortez
NY • D
Sponsored 2/5/2025
Omar
MN • D
Sponsored 2/5/2025
Pallone
NJ • D
Sponsored 2/5/2025
Perez
WA • D
Sponsored 2/5/2025
Pingree
ME • D
Sponsored 2/5/2025
Pocan
WI • D
Sponsored 2/5/2025
Pressley
MA • D
Sponsored 2/5/2025
Ramirez
IL • D
Sponsored 2/5/2025
Raskin
MD • D
Sponsored 2/5/2025
Riley (NY)
NY • D
Sponsored 2/5/2025
Ross
NC • D
Sponsored 2/5/2025
Ryan
NY • D
Sponsored 2/5/2025
Salinas
OR • D
Sponsored 2/5/2025
Scanlon
PA • D
Sponsored 2/5/2025
Schakowsky
IL • D
Sponsored 2/5/2025
Sherman
CA • D
Sponsored 2/5/2025
Smith (WA)
WA • D
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Soto
FL • D
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Stansbury
NM • D
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Stevens
MI • D
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Sykes
OH • D
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Takano
CA • D
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Thanedar
MI • D
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Thompson (MS)
MS • D
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Titus
NV • D
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Tlaib
MI • D
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Tokuda
HI • D
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Tonko
NY • D
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Torres (CA)
CA • D
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Trahan
MA • D
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Turner (TX)
TX • D
Sponsored 2/5/2025
Vargas
CA • D
Sponsored 2/5/2025
Velazquez
NY • D
Sponsored 2/5/2025
Wasserman Schultz
FL • D
Sponsored 2/5/2025
Waters
CA • D
Sponsored 2/5/2025
Watson Coleman
NJ • D
Sponsored 2/5/2025
Williams (GA)
GA • D
Sponsored 2/5/2025
Wilson (FL)
FL • D
Sponsored 2/5/2025
Torres (NY)
NY • D
Sponsored 2/6/2025
Schrier
WA • D
Sponsored 2/7/2025
Courtney
CT • D
Sponsored 3/4/2025
Cisneros
CA • D
Sponsored 3/4/2025
Levin
CA • D
Sponsored 3/5/2025
Suozzi
NY • D
Sponsored 3/6/2025
Scott, David
GA • D
Sponsored 4/24/2025
Sanchez
CA • D
Sponsored 4/24/2025
Simon
CA • D
Sponsored 5/7/2025
McDonald Rivet
MI • D
Sponsored 5/21/2025
Sorensen
IL • D
Sponsored 9/9/2025
Bell
MO • D
Sponsored 9/18/2025
Harder (CA)
CA • D
Sponsored 12/4/2025
Grijalva
AZ • D
Sponsored 2/3/2026
Roll Call Votes
No roll call votes available for this bill.
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