Bill
HR 995
Restricts multinational tax avoidance by tightening CFC income inclusion, country-by-country tax credits, and inversions, while treating U.S.-managed foreign firms as domestic.
Note on source materials
- The bill metadata supplied identifies H.R. 995 as a House resolution “Commending Samuel Yates for his service…” (classification: Congratulatory & Honorary) and shows the measure was placed on the Congratulatory & Memorial Resolutions calendar and adopted by the House (reported enrolled) on May 23, 2025.
- The legislative text provided with the request, however, is a substantive tax measure titled the “No Tax Breaks for Outsourcing Act,” which would amend the Internal Revenue Code. Because the object and text conflict, this summary (below) focuses on the substantive text you provided while noting the procedural/metadata inconsistency. Consult the official congressional record or Congress.gov for the authoritative final text/status of H.R. 995.
Purpose and intent
- Short title: “No Tax Breaks for Outsourcing Act.”
- Broad intent (from section headings): to tighten U.S. international tax rules to prevent tax avoidance via foreign subsidiaries and inversions, to limit interest deductions that erode the U.S. tax base, and to treat certain foreign corporations as domestic where managed and controlled in the United States.
Key provisions (as reflected in the provided table of contents)
1. Short title and statutory references
- Confirms citation and states that amendments/repeals refer to the Internal Revenue Code of 1986 unless otherwise noted.
Current-year inclusion of net CFC tested income
Country-by-country application of limitation on foreign tax credit based on taxable units
Limitation on deduction of interest by domestic corporations in international financial reporting groups
Modifications to rules relating to inverted corporations
Treatment of foreign corporations managed and controlled in the United States as domestic corporations
Who would be affected
- Multinational corporations with U.S. parents or U.S. shareholders (CFC regimes).
- Corporations that shift profits or debt across borders to reduce U.S. tax (base erosion/interest‑deduction strategies).
- Companies that have completed or may consider inversion transactions.
- Foreign corporations with management/control in the U.S. that would be reclassified for U.S. tax purposes.
- Potentially increased IRS compliance and reporting burdens for affected taxpayers.
Procedural status and timeline (per supplied actions)
- Introduced in the House: February 5, 2025; referred to House Committee on Ways and Means.
- The metadata shows the measure was placed on the Congratulatory & Memorial Res. Calendar, laid before the House, adopted, and reported enrolled on May 23, 2025 — consistent with passage of a noncontroversial House resolution, not necessarily with enactment of a complex tax statute.
- A companion bill is listed as S. 409.
Potential impacts and considerations
- If enacted as tax law, this package could raise federal revenue, reduce incentives for outsourcing and profit shifting, and broaden U.S. taxable income for many multinationals.
- Could increase compliance costs and trigger international tax disputes or treaty questions (country‑by‑country credits and reclassification of entities).
- The absence of detailed statutory text, numeric thresholds, or effective dates in the supplied summary limits precision about revenue impact and timing.
Recommendation
- Because of the clear discrepancy between the bill metadata (a commendatory resolution) and the substantive tax text provided, verify the official H.R. 995 entry on Congress.gov or the House Clerk’s website to confirm which text is the official enrolled bill and to obtain full statutory language, effective dates, and any Congressional Budget Office (CBO) estimates.
Compiled from official sources — confirm details with the bill’s official record.
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