No Tax Breaks for Outsourcing Act

The "No Tax Breaks for Outsourcing Act" (S 409) amends U.S. tax rules to prevent corporations from avoiding taxes through foreign operations. It changes the definition of taxable foreign income from "global intangible low-taxed income" to "net CFC tested income" and requires country-by-country reporting of income for tax purposes. The bill also limits interest deductions for certain corporations in international financial reporting groups and modifies rules for "inverted corporations" (foreign companies that acquire U.S. companies to avoid taxes). These changes aim to close tax loopholes that allow companies to outsource operations to foreign jurisdictions while reducing their U.S. tax burden. The bill's provisions would generally apply to taxable years beginning after December 31, 2024.