Us Congress 2023-2024 Regular Session

Us Congress Senate Bill SB357

Introduced
2/9/23  

Caption

No Tax Breaks for Outsourcing Act

Impact

If enacted, SB357 would significantly reshape how U.S. multinational corporations are taxed by requiring them to include net CFC tested income in their taxable income calculations immediately. This inclusion is designed to discourage the shifting of profits to low-tax jurisdictions and would enhance revenue for the federal government. Furthermore, the bill limits deductions for domestic corporations that belong to international financial reporting groups, which could lead to increased tax obligations for such corporations. The legislation aims to curtail practices perceived as tax avoidance by aligning tax liabilities more closely with the locations of profits generated.

Summary

SB357, titled the 'No Tax Breaks for Outsourcing Act', aims to amend the Internal Revenue Code of 1986 with provisions focused on the taxation of controlled foreign corporations (CFCs). The bill advocates for the current year inclusion of net CFC tested income, thereby eliminating the tax-free return on investments by CFCs. It seeks to create a more tightly regulated system for international financial operations of U.S. corporations, ensuring that income earned abroad is accounted for in current taxation periods, rather than deferring tax obligations to future periods.

Contention

The bill's measures have drawn attention and criticism, particularly concerning the potential burden placed on businesses operating internationally. Critics argue that these changes could hamper the competitiveness of U.S. businesses in the global market by imposing higher taxes than foreign competitors, particularly those in jurisdictions with lower tax rates. Supporters contend that the legislation is a necessary step toward preventing tax base erosion and ensuring that U.S. corporations contribute a fair share to the federal tax system. Overall, the debate centers around the balance between curbing tax avoidance and maintaining a competitive tax environment for U.S. companies.

Companion Bills

US HB884

Same As No Tax Breaks for Outsourcing Act

US HB8268

Related Stop Corporate Inversions Act of 2024

US SB4275

Related Stop Corporate Inversions Act of 2024

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