This bill modifies tax provisions relating to certain large domestic and foreign corporations to prevent offshoring of jobs and factories and tax evasion.

Specifically, the bill

• restores higher tax rates on the taxable income of corporations and personal service corporations (up to 35% on taxable income exceeding $10 million);
• revises the definition of subpart F income for controlled foreign corporations to equalize tax rates on domestic and foreign corporations;
• requires multinational companies to disclose basic country-by-country information including revenues, profits, and number of employees;
• prohibits corporations from disregarding parts of their structure in determining whether they owe taxes in the current year or can defer payment (repeal of check-the-box rules);
• impose limitations on the tax deduction for the interest expense of members of financial reporting groups with excess domestic indebtedness;
• modifies rules relating to inverted corporations;
• treats corporations with gross assets of $50 million or more and managed and controlled in the United States as U.S. taxpayers;
• increases the rate and expands the applicability of the base erosion and anti-abuse excise tax;
• modifies foreign tax credit rules applicable to certain industries receiving specific economic benefits; and
• repeals the tax deduction for foreign-derived intangible income.