,,ii  #aafth ,,congress  #ast ,session  
,s4 #afaj  ,,in ,,the ,,senate ,,of     
,,the ,,united ,,states  ,may #bb1      
#bjai,ms4 ,klobuchar 7for herself1 ,mr4 
,van ,hollen1 and ,ms4 ,duckworth7      
introduced the following bill2 which was
 read twice and referred to the         
,committee on ,finance  ,a ,,bill  ,to  
amend the ,internal ,revenue ,code of   
#aihf to modify the global intangible   
low-taxed income by repealing the       
tax-free deemed return on investments   
and determining net ,,cfc tested income 
on a per-country basis4  #a4 ,short     
title ,this ,act may be cited as the    
,removing ,incentives for ,outsourcing  
,act4  #b4 ,modification of tax on      
global intangible low-taxed income  7a7 
,repeal of tax-,free deemed return on   
investments  7#a7 ,in general ,section  
#iea;,a7a7 of the ,internal ,revenue    
,code of #aihf is amended by striking   
global intangible low-taxed income and  
inserting net ,,cfc tested income4  7#b7
 ,conforming amendments  7,a7 ,section  

#iea;,a of such ,code is amended by     
striking subsections 7b7 and 7d74  7,b7 
,section #iea;,a7e77#a7 of such ,code is
 amended by striking subsections 7b71   
7c77#a77;,a71 and and inserting         
subsections 7c77#a77;,a7 and4  7,c7     
,section #iea;,a7f7 of such ,code is    
amended to read as follows3  7f7        
,treatment as subpart ,f income for     
certain purposes  7#a7 ,in general      
,except as provided in paragraph 7#b71  
any net ,,cfc tested income included in 
gross income under subsection 7a7 shall 
be treated in the same manner as an     
amount included under section           
#iea7;a77#a77;,a7 for purposes of       
applying sections #afh7;h77#b77;,b71    
#ece7;b77#aj71 #hea7;b71 #ijd7;h77#a71  
#iei1 #ifa1 #ifb1 #iic7;a77#a77;,e71    
#iif7;f77#a71 #abdh7;b77#a71            
#abdh7;d77#a71 #feja7;e77#a77;,c71      
#ffed7;d77#b77;,d71 and #ffee7;e77#d74  
7#b7 ,exception ,the ,secretary shall   
provide rules for the application of    
paragraph 7#a7 to other provisions of   

this title in any case in which the     
determination of subpart ,f income is   
required to be made at the level of the 
controlled foreign corporation4  4  7,d7
 ,section #ifj7;d77#b77;,a7 of such     
,code is amended by striking global     
intangible low-taxed income 7as defined 
in section #iea;,a7b77 and inserting net
 ,,cfc tested income 7as defined in     
section #iea;,a7c774  7b7 ,determination
 of net ,,cfc tested income on          
country-by-,country basis ,section      
#iea;,a of the ,internal ,revenue ,code 
of #aihf is amended by adding at the end
 the following3  7g7 ,determination made
 on country-by-,country basis  7#a7 ,in 
general ,this section shall be applied  
with respect to a ,united ,states       
shareholder of the controlled foreign   
corporation separately with respect to  
each foreign country in which the       
controlled foreign corporation conducts 
any trade or business4  7#b7 ,special   
rules  7,a7 ,in general ,for purposes of
 making country-by-country              

determinations under this section and   
sections #ijd and #ifj with respect to  
net ,,cfc tested income for a taxable   
year pursuant to paragraph 7#a7-- 7i7   
taxes paid or accrued to a foreign      
country by the controlled foreign       
corporation shall be assigned to that   
country1 and  7ii7 earnings to which    
such taxes relate shall be treated as   
income assigned to the country to which 
those tax payments are made4  7,b7      
,earnings assigned to two or more       
countries ,if the same earnings are     
assigned to two or more countries under 
subparagraph 7,a71 for purposes of      
paragraph 7#a7 such earnings and the    
taxes related thereto shall be treated  
as assigned to the country with the     
highest statutory corporate tax rate4   
7#c7 ,earnings not subject to tax ,if   
earnings are not subject to tax by any  
country1 then with respect to those     
earnings paragraph 7#a7 shall not apply4
  7#d7 ,regulations ,the ,secretary     
shall prescribe such regulations as may 

be necessary or appropriate to carry out
 this subsection1 including the time    
period in which foreign earnings and the
 associated foreign taxes are assigned  
to a country4  4  7c7 ,effective date   
,the amendments made by this section    
shall apply with respect to taxable     
years of controlled foreign corporations
 beginning after ,december #ca1 #bjai1  
and to taxable years of ,united ,states 
shareholders in which or with which such
 taxable years of foreign corporations  
end4  #c4 ,study and report on          
restructuring international tax laws    
7a7 ,study ,the ,chief of ,staff of the 
,joint ,committee on ,taxation shall    
study options for the reform of laws    
related to the taxation of income from  
international sources1 including the    
provisions of sections #ei;,a1 #bej1 and
 #iea;,a of the ,internal ,revenue ,code
 of #aihf4 ,such study include an       
evaluation of each option considered    
with respect to-- 7#a7 the extent to    
which the option increases or decreases 

opportunities for tax avoidance2 and    
7#b7 the extent to which the option     
increases or decreases incentives for   
domestic businesses to shift jobs and   
operations to other countries4  7b7     
,report ,not later than #ij days after  
the date of the enactment of this ,act1 
the ,chief of ,staff on the ,joint      
,committee on ,taxation shall submit to 
,congress a report on the results of the
 study conducted under subsection 7a74