1. Short title This Act may be cited as the Offshoring Prevention Act . 2. Taxation of income of controlled foreign corporations attributable to imported property (a) General Rule Subsection (a) of section 954 of the Internal Revenue Code of 1986 is amended by striking the period at the end of paragraph (5) and inserting , and , by redesignating paragraph (5) as paragraph (4), and by adding at the end the following new paragraph: (5) imported property income for the taxable year (determined under subsection (j) and reduced as provided in subsection (b)(5)). . (b) Definition of Imported Property Income Section 954 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection: (j) Imported Property Income (1) In general For purposes of subsection (a)(5), the term imported property income means income (whether in the form of profits, commissions, fees, or otherwise) derived in connection with— (A) manufacturing, producing, growing, or extracting imported property; (B) the sale, exchange, or other disposition of imported property; or (C) the lease, rental, or licensing of imported property. Such term shall not include any foreign oil and gas extraction income (within the meaning of section 907(c)) or any foreign oil related income (within the meaning of section 907(c)). (2) Imported property For purposes of this subsection— (A) In general Except as otherwise provided in this paragraph, the term imported property means property which is imported into the United States by the controlled foreign corporation or a related person. (B) Imported property includes certain property imported by unrelated persons The term imported property includes any property imported into the United States by an unrelated person if, when such property was sold to the unrelated person by the controlled foreign corporation (or a related person), it was reasonable to expect that— (i) such property would be imported into the United States