Creating American Jobs and Ending Offshoring Act

Creating American Jobs and Ending Offshoring Act - Amends the Internal Revenue Code to: (1) exempt from employment taxes for a 24-month period employers who hire a employee who replaces another employee who is not a citizen or permanent resident of the United States and who performs similar duties overseas; (2) deny any tax deduction, deduction for loss, or tax credit for the cost of an American jobs offshoring transaction (defined as any transaction in which a taxpayer reduces or eliminates the operation of a trade or business in connection with the start-up or expansion of such trade or business outside the United States); and (3) eliminate the deferral of tax on income of a controlled foreign corporation attributable to property imported into the United States by such corporation or a related person, except for property exported before substantial use in the United States and for agricultural commodities not grown in the United States in commercially marketable quantities.