This bill amends the Internal Revenue Code to limit the tax deduction available to certain foreign-controlled U.S. multinational corporations for excess interest on debt incurred by such corporations (i.e., earnings stripping) by: (1) repealing the debt-to-equity ratio threshold required for such deduction, (2) reducing the permitted net interest expense threshold from 50% to 25% of the corporation's adjusted taxable income, (3) repealing the excess limitation carryforward, and (4) limiting to five years the carryforward of disallowed interest expenses with respect to amounts paid or incurred before, on, or after the date of enactment of this bill.