1. Short title This Act may be cited as the Removing Incentives for Outsourcing Act . 2. Modification of tax on global intangible low-taxed income (a) Repeal of tax-Free deemed return on investments (1) In general Section 951A(a) of the Internal Revenue Code of 1986 is amended by striking global intangible low-taxed income and inserting net CFC tested income . (2) Conforming amendments (A) Section 951A of such Code is amended by striking subsections (b) and (d). (B) Section 951A(e)(1) of such Code is amended by striking subsections (b), (c)(1)(A), and and inserting subsections (c)(1)(A) and . (C) Section 951A(f) of such Code is amended to read as follows: (f) Treatment as subpart F income for certain purposes (1) In general Except as provided in paragraph (2), any net CFC tested income included in gross income under subsection (a) shall be treated in the same manner as an amount included under section 951(a)(1)(A) for purposes of applying sections 168(h)(2)(B), 535(b)(10), 851(b), 904(h)(1), 959, 961, 962, 993(a)(1)(E), 996(f)(1), 1248(b)(1), 1248(d)(1), 6501(e)(1)(C), 6654(d)(2)(D), and 6655(e)(4). (2) Exception The Secretary shall provide rules for the application of paragraph (1) 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 corporation. . (D) Section 960(d)(2)(A) of such Code is amended by striking global intangible low-taxed income (as defined in section 951A(b)) and inserting net CFC tested income (as defined in section 951A(c)) . (b) Determination of net CFC tested income on country-by-Country basis Section 951A of the Internal Revenue Code of 1986 is amended by adding at the end the following: (g) Determination made on country-by-Country basis (1) 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 business. (2)