Draft Bill Introduced in U.S. Senate to Amend CFC/GILTI Rules

Senator Amy Klobuchar (D-MN) has introduced the Removing Incentives for Outsourcing Act (Bill S. 3674) in the U.S. Senate, which would amend the Internal Revenue Code to modify the global intangible low-taxed income (GILTI) by repealing the tax-free deemed return on investments and determining net CFC tested income on a per-country basis. Bill S. 3674 is similar to a bill introduced in the House in June 2018, the Per-Country Minimum Act ({News-2018-06-11/P/5-previous coverage}), although the …