The administration called for U.S. taxes on excessive profits from the offshore use of transferred intangibles.
The plan also called for a credit against income tax equal to 20 percent of the expenses paid or incurred in connection with “insourcing” a U.S. trade or business. Deductions for expenses paid or incurred in connection with “outsourcing” a U.S. trade or business would be disallowed.
Also in the Green Book, the administration proposed disallowing the deduction for domestic production activities for oil and other fossil fuel production.
In a fact sheet, the administration said that in addition to stopping transfer pricing abuses, the budget would delay the deduction for the interest expense attributable to overseas investment.
Read more at: Tax Times blog