No Tax Breaks for Outsourcing Act
Sponsored By: Representative Doggett, Lloyd [D-TX-37]
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, Lloyd [D-TX-37]
TX • D
Cosponsors
Adams
NC • D
Sponsored 2/5/2025
Rep. Ansari, Yassamin [D-AZ-3]
AZ • D
Sponsored 2/5/2025
Rep. Balint, Becca [D-VT-At Large]
VT • D
Sponsored 2/5/2025
Barragan
CA • D
Sponsored 2/5/2025
Rep. Beatty, Joyce [D-OH-3]
OH • D
Sponsored 2/5/2025
Bishop
GA • D
Sponsored 2/5/2025
Bonamici
OR • D
Sponsored 2/5/2025
Rep. Boyle, Brendan F. [D-PA-2]
PA • D
Sponsored 2/5/2025
Rep. Brown, Shontel M. [D-OH-11]
OH • D
Sponsored 2/5/2025
Rep. Brownley, Julia [D-CA-26]
CA • D
Sponsored 2/5/2025
Budzinski
IL • D
Sponsored 2/5/2025
Carson
IN • D
Sponsored 2/5/2025
Rep. Carter, Troy A. [D-LA-2]
LA • D
Sponsored 2/5/2025
Rep. Casar, Greg [D-TX-35]
TX • D
Sponsored 2/5/2025
Rep. Case, Ed [D-HI-1]
HI • D
Sponsored 2/5/2025
Rep. Chu, Judy [D-CA-28]
CA • D
Sponsored 2/5/2025
Rep. Clarke, Yvette D. [D-NY-9]
NY • D
Sponsored 2/5/2025
Rep. Cleaver, Emanuel [D-MO-5]
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
Sponsored 2/5/2025
Rep. Dean, Madeleine [D-PA-4]
PA • D
Sponsored 2/5/2025
Rep. McClain Delaney, April [D-MD-6]
MD • D
Sponsored 2/5/2025
Rep. DeLauro, Rosa L. [D-CT-3]
CT • D
Sponsored 2/5/2025
DelBene
WA • D
Sponsored 2/5/2025
Rep. Deluzio, Christopher R. [D-PA-17]
PA • D
Sponsored 2/5/2025
Rep. DeSaulnier, Mark [D-CA-10]
CA • D
Sponsored 2/5/2025
Rep. Dexter, Maxine [D-OR-3]
OR • D
Sponsored 2/5/2025
Rep. Dingell, Debbie [D-MI-6]
MI • D
Sponsored 2/5/2025
Escobar
TX • D
Sponsored 2/5/2025
Espaillat
NY • D
Sponsored 2/5/2025
Rep. Evans, Dwight [D-PA-3]
PA • D
Sponsored 2/5/2025
Rep. Leger Fernandez, Teresa [D-NM-3]
NM • D
Sponsored 2/5/2025
Rep. Foster, Bill [D-IL-11]
IL • D
Sponsored 2/5/2025
Rep. Foushee, Valerie P. [D-NC-4]
NC • D
Sponsored 2/5/2025
Rep. Frankel, Lois [D-FL-22]
FL • D
Sponsored 2/5/2025
Rep. Frost, Maxwell [D-FL-10]
FL • D
Sponsored 2/5/2025
Rep. Garamendi, John [D-CA-8]
CA • D
Sponsored 2/5/2025
Rep. García, Jesús G. "Chuy" [D-IL-4]
IL • D
Sponsored 2/5/2025
Rep. Garcia, Robert [D-CA-42]
CA • D
Sponsored 2/5/2025
Rep. Garcia, Sylvia R. [D-TX-29]
TX • D
Sponsored 2/5/2025
Rep. Golden, Jared F. [D-ME-2]
ME • D
Sponsored 2/5/2025
Rep. Goldman, Daniel S. [D-NY-10]
NY • D
Sponsored 2/5/2025
Gomez
CA • D
Sponsored 2/5/2025
Rep. Green, Al [D-TX-9]
TX • D
Sponsored 2/5/2025
Grijalva
AZ • D
Sponsored 2/5/2025
Rep. Hayes, Jahana [D-CT-5]
CT • D
Sponsored 2/5/2025
Rep. Horsford, Steven [D-NV-4]
NV • D
Sponsored 2/5/2025
Rep. Hoyle, Val T. [D-OR-4]
OR • D
Sponsored 2/5/2025
Rep. Huffman, Jared [D-CA-2]
CA • D
Sponsored 2/5/2025
Ivey
MD • D
Sponsored 2/5/2025
Jackson (IL)
IL • D
Sponsored 2/5/2025
Rep. Jayapal, Pramila [D-WA-7]
WA • D
Sponsored 2/5/2025
Johnson (GA)
GA • D
Sponsored 2/5/2025
Rep. Kaptur, Marcy [D-OH-9]
OH • D
Sponsored 2/5/2025
Rep. Kelly, Robin L. [D-IL-2]
IL • D
Sponsored 2/5/2025
Kennedy (NY)
NY • D
Sponsored 2/5/2025
Khanna
CA • D
Sponsored 2/5/2025
Rep. Landsman, Greg [D-OH-1]
OH • D
Sponsored 2/5/2025
Rep. Larson, John B. [D-CT-1]
CT • D
Sponsored 2/5/2025
Rep. Lee, Summer L. [D-PA-12]
PA • D
Sponsored 2/5/2025
Rep. Lieu, Ted [D-CA-36]
CA • D
Sponsored 2/5/2025
Rep. Lynch, Stephen F. [D-MA-8]
MA • D
Sponsored 2/5/2025
Rep. Magaziner, Seth [D-RI-2]
RI • D
Sponsored 2/5/2025
McBath
GA • D
Sponsored 2/5/2025
McBride
DE • D
Sponsored 2/5/2025
McCollum
MN • D
Sponsored 2/5/2025
Rep. McGarvey, Morgan [D-KY-3]
KY • D
Sponsored 2/5/2025
McGovern
MA • D
Sponsored 2/5/2025
Rep. Meeks, Gregory W. [D-NY-5]
NY • D
Sponsored 2/5/2025
Rep. Menendez, Robert [D-NJ-8]
NJ • D
Sponsored 2/5/2025
Rep. Meng, Grace [D-NY-6]
NY • D
Sponsored 2/5/2025
Mfume
MD • D
Sponsored 2/5/2025
Rep. Moulton, Seth [D-MA-6]
MA • D
Sponsored 2/5/2025
Mrvan
IN • D
Sponsored 2/5/2025
Rep. Nadler, Jerrold [D-NY-12]
NY • D
Sponsored 2/5/2025
Rep. Neguse, Joe [D-CO-2]
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
Rep. Omar, Ilhan [D-MN-5]
MN • D
Sponsored 2/5/2025
Pallone
NJ • D
Sponsored 2/5/2025
Rep. Perez, Marie Gluesenkamp [D-WA-3]
WA • D
Sponsored 2/5/2025
Pingree
ME • D
Sponsored 2/5/2025
Rep. Pocan, Mark [D-WI-2]
WI • D
Sponsored 2/5/2025
Rep. Pressley, Ayanna [D-MA-7]
MA • D
Sponsored 2/5/2025
Rep. Ramirez, Delia C. [D-IL-3]
IL • D
Sponsored 2/5/2025
Rep. Raskin, Jamie [D-MD-8]
MD • D
Sponsored 2/5/2025
Riley (NY)
NY • D
Sponsored 2/5/2025
Rep. Ross, Deborah K. [D-NC-2]
NC • D
Sponsored 2/5/2025
Rep. Ryan, Patrick [D-NY-18]
NY • D
Sponsored 2/5/2025
Rep. Salinas, Andrea [D-OR-6]
OR • D
Sponsored 2/5/2025
Rep. Scanlon, Mary Gay [D-PA-5]
PA • D
Sponsored 2/5/2025
Schakowsky
IL • D
Sponsored 2/5/2025
Rep. Sherman, Brad [D-CA-32]
CA • D
Sponsored 2/5/2025
Smith (WA)
WA • D
Sponsored 2/5/2025
Soto
FL • D
Sponsored 2/5/2025
Stansbury
NM • D
Sponsored 2/5/2025
Rep. Stevens, Haley M. [D-MI-11]
MI • D
Sponsored 2/5/2025
Rep. Sykes, Emilia Strong [D-OH-13]
OH • D
Sponsored 2/5/2025
Rep. Takano, Mark [D-CA-39]
CA • D
Sponsored 2/5/2025
Rep. Thanedar, Shri [D-MI-13]
MI • D
Sponsored 2/5/2025
Thompson (MS)
MS • D
Sponsored 2/5/2025
Rep. Titus, Dina [D-NV-1]
NV • D
Sponsored 2/5/2025
Rep. Tlaib, Rashida [D-MI-12]
MI • D
Sponsored 2/5/2025
Rep. Tokuda, Jill N. [D-HI-2]
HI • D
Sponsored 2/5/2025
Rep. Tonko, Paul [D-NY-20]
NY • D
Sponsored 2/5/2025
Rep. Torres, Norma J. [D-CA-35]
CA • D
Sponsored 2/5/2025
Trahan
MA • D
Sponsored 2/5/2025
Turner (TX)
TX • D
Sponsored 2/5/2025
Rep. Vargas, Juan [D-CA-52]
CA • D
Sponsored 2/5/2025
Rep. Velázquez, Nydia M. [D-NY-7]
NY • D
Sponsored 2/5/2025
Rep. Wasserman Schultz, Debbie [D-FL-25]
FL • D
Sponsored 2/5/2025
Rep. Waters, Maxine [D-CA-43]
CA • D
Sponsored 2/5/2025
Rep. Watson Coleman, Bonnie [D-NJ-12]
NJ • D
Sponsored 2/5/2025
Rep. Williams, Nikema [D-GA-5]
GA • D
Sponsored 2/5/2025
Wilson (FL)
FL • D
Sponsored 2/5/2025
Rep. Torres, Ritchie [D-NY-15]
NY • D
Sponsored 2/6/2025
Schrier
WA • D
Sponsored 2/7/2025
Rep. Courtney, Joe [D-CT-2]
CT • D
Sponsored 3/4/2025
Cisneros
CA • D
Sponsored 3/4/2025
Levin
CA • D
Sponsored 3/5/2025
Rep. Suozzi, Thomas R. [D-NY-3]
NY • D
Sponsored 3/6/2025
Scott, David
GA • D
Sponsored 4/24/2025
Rep. Sánchez, Linda T. [D-CA-38]
CA • D
Sponsored 4/24/2025
Simon
CA • D
Sponsored 5/7/2025
Rep. McDonald Rivet, Kristen [D-MI-8]
MI • D
Sponsored 5/21/2025
Rep. Sorensen, Eric [D-IL-17]
IL • D
Sponsored 9/9/2025
Rep. Bell, Wesley [D-MO-1]
MO • D
Sponsored 9/18/2025
Rep. Harder, Josh [D-CA-9]
CA • D
Sponsored 12/4/2025
Grijalva
AZ • D
Sponsored 2/3/2026
Roll Call Votes
No roll call votes available for this bill.
View on Congress.gov