be treated as a single taxpayer. (e) Regulations The Secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section. . (b) Clerical amendment The table of sections for part IX of subchapter B of chapter 1 of the Internal Revenue Code of 1986, as amended by section 3, is amended by adding at the end the following new item: Sec. 280J. Limitations for outsourcing employers. . (c) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act. 5. Current year inclusion of net CFC tested 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