No Tax Breaks for Outsourcing Act
Sponsored By: Senator Sen. Whitehouse, Sheldon [D-RI]
Introduced
Summary
This bill would deliver a broad overhaul of U.S. international tax rules, primarily to end special low rates for offshore profits and tighten rules that let multinationals shift income abroad. It replaces the GILTI system with a current‑year inclusion for 'net CFC tested income' and repeals Section 250 reduced‑rate benefits for foreign‑derived intangible income.
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Bill Overview
Analyzed Economic Effects
4 provisions identified: 1 benefits, 2 costs, 1 mixed.
Some foreign companies treated as U.S.
This bill would treat some foreign corporations as domestic if management and control is mainly in the U.S. It covers firms regularly traded publicly or with $50,000,000 or more in assets. The Treasury would write rules to decide when U.S. management counts. The rule starts two years after the bill is enacted.
Tighter rules on corporate inversions
This bill would make more foreign parents treated as U.S. companies after inversions. It raises the surrogate test to 80% and adds post-deal ownership and U.S. management tests. The rule applies to tax years ending after Dec 22, 2017 and allows three-year assessments to enforce the changes.
New rules for U.S. multinational taxes
This bill would replace GILTI with a new per-country "net CFC tested income" rule. U.S. shareholders would include current-year net CFC income country-by-country. It would repeal the low-rate deduction for FDII/GILTI and narrow some exclusions. It would let deemed-paid foreign tax credits for tested income be claimed at 100%. It would stop foreign tax credit carrybacks and only allow carryforwards for up to 10 years. The IRS would write rules for allocation, oil income, and anti-avoidance. Most changes would start for tax years beginning after Dec 31, 2024.
Five-year carryforward for disallowed interest
This bill would let companies use interest disallowed under current limits in later years. Disallowed interest could be used for up to five years and must be used FIFO. This applies to tax years beginning after Dec 31, 2024.
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Sponsors & CoSponsors
Sponsor
Sen. Whitehouse, Sheldon [D-RI]
RI • D
Cosponsors
Sen. Durbin, Richard J. [D-IL]
IL • D
Sponsored 2/5/2025
Sen. Murphy, Christopher [D-CT]
CT • D
Sponsored 2/5/2025
Sen. Reed, Jack [D-RI]
RI • D
Sponsored 2/5/2025
Sen. Baldwin, Tammy [D-WI]
WI • D
Sponsored 2/5/2025
Sen. Warren, Elizabeth [D-MA]
MA • D
Sponsored 2/5/2025
Sen. Merkley, Jeff [D-OR]
OR • D
Sponsored 2/5/2025
Sen. Markey, Edward J. [D-MA]
MA • D
Sponsored 2/5/2025
Sen. Schatz, Brian [D-HI]
HI • D
Sponsored 2/5/2025
Sen. Fetterman, John [D-PA]
PA • D
Sponsored 2/5/2025
Richard Blumenthal
CT • D
Sponsored 2/5/2025
Chris Van Hollen
MD • D
Sponsored 2/5/2025
Sen. Gallego, Ruben [D-AZ]
AZ • D
Sponsored 2/5/2025
Sen. Hirono, Mazie K. [D-HI]
HI • D
Sponsored 2/5/2025
Sen. Heinrich, Martin [D-NM]
NM • D
Sponsored 2/5/2025
Sen. Booker, Cory A. [D-NJ]
NJ • D
Sponsored 2/5/2025
Sen. Smith, Tina [D-MN]
MN • D
Sponsored 2/5/2025
Tammy Duckworth
IL • D
Sponsored 2/5/2025
Peter Welch
VT • D
Sponsored 2/24/2025
Sen. Luján, Ben Ray [D-NM]
NM • D
Sponsored 4/1/2025
Roll Call Votes
No roll call votes available for this bill.
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