S. 357
118th Congress
Senate
No Tax Breaks for Outsourcing Act
Official title: A bill to amend the Internal Revenue Code of 1986 to provide for current year inclusion of net CFC tested income, and for other purposes.
Taxation
Accounting and auditingCorporate finance and managementForeign and international corporationsIncome tax credits
More subjectsShow fewer subjects
Income tax deductionsInterest, dividends, interest ratesOil and gasTax administration and collection, taxpayersTaxation of foreign incomeU.S. and foreign investments
Everywhere this bill has been
2 steps
Introduced
In committee
Reported out
Passed House
Passed Senate
To President
Became law
Feb 9, 2023
Read twice and referred to the Committee on Finance.
Feb 9, 2023
Introduced in Senate
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Latest action
Read twice and referred to the Committee on Finance.
Plain-English summary
No Tax Breaks for Outsourcing Act
This bill modifies the tax treatment of the foreign source income of domestic corporations. The bill includes provisions that
- modify calculations of the gross income of U.S. shareholders to include net controlled foreign corporation (CFC) tested income in the current taxable year;
- apply limitations on the foreign tax credit on a country-by-country basis;
- limit the tax deduction for the interest expense of a U.S. corporation that is a member of an international financial reporting group (i.e., a group that prepares consolidated financial statements according to generally accepted accounting principles or international financial reporting standards);
- modify the rules for the taxation of inverted corporations (i.e., U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States); and
- treat certain foreign corporations managed and controlled primarily in the United States as domestic corporations for tax purposes.
Related & companion bills
3
Bill text
1 version
- Introduced in Senate Formatted Text PDF Formatted XML
Committees of jurisdiction
1
Cite this page
U.S. Congress. (2026). S. 357: No Tax Breaks for Outsourcing Act. 118th Congress. Open America. https://openamerica.io/bill/118-S-357/
"S. 357: No Tax Breaks for Outsourcing Act." 118th Congress, 2026, Open America, https://openamerica.io/bill/118-S-357/.
S. 357, 118th Cong. (2026), https://openamerica.io/bill/118-S-357/.
[S. 357: No Tax Breaks for Outsourcing Act](https://openamerica.io/bill/118-S-357/)