119 S2976 IS: Halting International Relocation of Employment Act
U.S. Senate
2025-10-06
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EN
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II
119th CONGRESS
1st Session
S. 2976
IN THE SENATE OF THE UNITED STATES
October 6, 2025
Mr. Moreno introduced the following bill; which was read twice and referred to the Committee on Finance
A BILL
To amend the Internal Revenue Code of 1986 to impose an excise tax on payments by United States taxpayers to foreign persons for services provided to United States consumers, and for other purposes.
1.

Short title
This Act may be cited as the “Halting International Relocation of Employment Act” or the “HIRE Act”.
2.

Outsourcing excise tax
(a)

In general
Subtitle D of the Internal Revenue Code of 1986 is amended by adding at the end the following new chapter:
“50B

Outsourcing
Sec. 5000E. Outsourcing payments.
5000E.

Outsourcing payments
(a)

Imposition of tax
There is hereby imposed a tax on any United States person making an outsourcing payment a tax equal to 25 percent of the amount of such payment.
(b)

Outsourcing payment
For purposes of this section—
(1)

In general
The term outsourcing payment means any premium, fee, royalty, service charge, or other payment made—
(A)
in the course of a trade or business,
(B)
to a foreign person, and
(C)
with respect to labor or services the benefit of which is directed, directly or indirectly, to consumers located in the United States.
(2)

Mixed payments
In the case of any payment to a foreign person with respect to which labor or services are directed to consumers both within and without the United States, the amount treated as an outsourcing payment shall not exceed the amount equal to the product of such payment and a fraction—
(A)
the numerator of which is the amount of labor or services with respect to such payment directed to consumers within the United States, to
(B)
the labor or services with respect to such payment directed to all consumers.
(c)

Foreign person
For purposes of this section, the term foreign person means any person who is not a United States person, except that such term shall not include any corporation or partnership which is organized under the laws of a possession of the United States.
(d)

Regulations and other guidance
The Secretary shall prescribe such regulations and other guidance as may be necessary or appropriate to carry out this section, including regulations or guidance to prevent the avoidance or abuse of the purposes of this section, including through the use of related parties, controlled foreign corporations, and other intermediaries, or through the use of transfer pricing arrangements.”.
(b)

Tax not deductible
Section 275(a)(6) of the Internal Revenue Code of 1986 is amended by inserting “50B,” after “50A”.
(c)

Reporting
The Secretary of the Treasury, or the Secretary's delegate, may—
(1)
require United States persons making payments to foreign persons (as defined in section 5000E of the Internal Revenue Code of 1986, as added by subsection (a)) to file a return of tax under section 5000E of such Code or to file an information return concerning such payments, which may include—
(A)
information on whether such payments are outsourcing payments (as defined in section 5000E of such Code), and
(B)
such other information concerning such payment as the Secretary may reasonably require to enforce the amendments made by this section, and
(2)
require the officers of any corporation to certify on such return, under penalty of perjury, the character of such payments.
For purposes part II of subchapter B of chapter 68 of the Internal Revenue Code of 1986, any return required to be filed under paragraph (1) shall be treated as an information return.
(d)

Increased penalty for failure To pay tax
Section 6651(a) of the Internal Revenue Code is amended by adding at the end the following new sentence: “In the case of the failure to pay any tax imposed under chapter 50B, paragraphs (2) and (3) shall be applied by substituting “50 percent” for “05. percent” each place it appears and without regard to the phrase “not exceeding 25 percent in the aggregate” each place it appears.”.
(e)

No inference
Nothing in this section or the amendments made by this section shall be construed to limit the application of the economic substance doctrine with respect to any payment described in section 5000E(b) of the Internal Revenue Code of 1986, as added by subsection (a).
(f)

Clerical amendment
The table of chapters for subpart D of the Internal Revenue Code of 1986 is amended by adding at the end the following new item:
“Chapter 50B—Outsourcing”.
(g)

Effective date
The amendments made by this section shall apply to payments made after December 31, 2025.
3.

Domestic workforce fund
(a)

In general
Subchapter A of chapter 98 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section:
“9512.

Domestic workforce fund
(a)

Establishment
There is established in the Treasury of the United States a trust fund to be known as the “Domestic Workforce Fund” (hereafter in this section referred to as the “Fund”), consisting of such amounts as may be appropriated, credited, or paid into the Fund as provided in this section or section 9602(b).
(b)

Transfer to fund
There are hereby appropriated to the Fund amounts equivalent to the amounts received in the Treasury under—
(1)
the tax imposed under section 5000E,
(2)
so much of the additions to tax under section 6051(a) as relates to the failure to pay taxes imposed under section 5000E, and
(3)
so much of the penalties imposed under part II of suchchapter B of chapter 68 as relates to returns described in section 2(b) of the Halting International Relocation of Employment Act.
(c)

Expenditures from fund
Amounts in the Fund shall be available, without further appropriation, solely for the following purposes:
(1)
Workforce development and retraining programs administered by the Department of Labor.
(2)
Apprenticeship programs and partnerships with industry to expand domestic employment in sectors impacted by outsourcing.
(3)
Grants to States for workforce development initiatives targeted at communities with high levels of job displacement.”.
(b)

Clerical amendment
The table of sections for subchapter A of chapter 98 of such Code is amended by adding at the end the following new item:
“Sec. 9512. Domestic workforce fund.”.
4.

Denial of income tax deduction on outsourcing payments
(a)

In general
Part IX of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section:
“280I.

Outsourcing payments
No deduction shall be allowed under this chapter for any outsourcing payment (as defined in section 5000E(b)).”.
(b)

Clerical amendment
The table of section for part IX of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new item:
“Sec. 280I. Outsourcing payments.”.
(c)

Effective date
The amendments made by this section shall apply to payments made after December 31, 2025, in taxable years ending after such date.