1. Short title, etc (a) Short title This Act may be cited as the No Tax Breaks for Outsourcing Act . (b) Amendment of 1986 code Except as otherwise expressly provided, whenever in this Act an amendment or repeal is expressed in terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1986. (c) Table of contents The table of contents of this Act is as follows: Sec. 1. Short title, etc. Sec. 2. Current year inclusion of net CFC tested income. Sec. 3. Country-by-country application of limitation on foreign tax credit based on taxable units. Sec. 4. Limitation on deduction of interest by domestic corporations which are members of an international financial reporting group. Sec. 5. Modifications to rules relating to inverted corporations. Sec. 6. Treatment of foreign corporations managed and controlled in the United States as domestic corporations. 2. Current year inclusion of net CFC tested income (a) Repeal of tax-Free deemed return on investments (1) In general Section 951A(a) is amended by striking global intangible low-taxed income and inserting net CFC tested income . (2) Conforming amendments (A) Section 951A is amended by striking subsections (b) and (d). (B) Section 951A(e)(1) is amended by striking subsections (b), (c)(1)(A), and and inserting subsections (c)(1)(A) and . (C) Section 951A(f) is amended by striking global intangible low-taxed income each place it appears and inserting net CFC tested income . (D) Section 960(d)(2)(A) 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) Country-by-Country application of section based on CFC taxable units Section 951A is amended by adding at the end the following new subsection: (g) Country-by-Country application of section based on CFC taxable units (1) In general If any CFC taxable unit of a United States shareholder is a tax