insourcing expenses shall be taken into account 
under subsection (a) in the first taxable year after 
the taxable year described in paragraph (1). 
‘‘(e) POSSESSIONS TREATED
AS PART
OF
THE 
UNITED STATES.—For purposes of this section, the term 
‘United States’ shall be treated as including each posses-
sion of the United States (including the Commonwealth 
of Puerto Rico and the Commonwealth of the Northern 
Mariana Islands). 
‘‘(f) REGULATIONS.—The Secretary shall prescribe 
such regulations or other guidance as may be necessary 
or appropriate to carry out the purposes of this section.’’. 
(b) CREDIT TO BE PART OF GENERAL BUSINESS 
CREDIT.—Section 38(b) of such Code is amended by strik-
ing ‘‘plus’’ at the end of paragraph (32), by striking the 
period at the end of paragraph (33) and inserting ‘‘, plus’’, 
and by adding at the end the following new paragraph: 
‘‘(34) the insourcing expenses credit determined 
under section 45U(a).’’. 
(c) CONFORMING AMENDMENTS.— 
(1) Section 280C of such Code is amended by 
adding at the end the following new subsection: 
‘‘(i) CREDIT FOR INSOURCING EXPENSES.—No de-
duction shall be allowed for that portion of the expenses 
otherwise allowable as a deduction taken into account in 
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determining the credit under section 45U for the taxable 
year which is equal to the amount of the credit determined 
for such taxable year under section 45U(a).’’. 
(2) The table of sections for subpart D of part 
IV of subchapter A of chapter 1 of such Code is 
amended by adding at the end the following new 
item: 
‘‘Sec. 45U. Credit for insourcing expenses.’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to amounts paid or incurred after 
the date of the enactment of this Act. 
(e) APPLICATION
TO
UNITED
STATES
POSSES-
SIONS.— 
(1) PAYMENTS TO POSSESSIONS.— 
(A) MIRROR
CODE
POSSESSIONS.—The 
Secretary of the Treasury shall make periodic 
payments to the United States Virgin Islands, 
Guam, and the Commonwealth of the Northern 
Mariana Islands in an amount equal to the loss 
to that possession by reason of section 45U of 
the Internal Revenue Code of 1986. Such 
amount shall be determined by the Secretary of 
the Treasury based on information provided by 
the government of the respective possession. 
(B) OTHER POSSESSIONS.—The Secretary 
of the Treasury shall make annual payments to 
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the Commonwealth of Puerto Rico and Amer-
ican Samoa in an amount estimated by the Sec-
retary of the Treasury as being equal to the ag-
gregate benefits that would have been provided 
to residents of each such possession by reason 
of section 45U of such Code if a mirror code 
tax system had been in effect in such posses-
sion. The preceding sentence shall not apply 
with respect to any possession of the United 
States unless such possession has a plan, which 
has been approved by the Secretary of the 
Treasury, under which such possession will 
promptly distribute such payment to the resi-
dents of such possession. 
(2) COORDINATION
WITH
CREDIT
ALLOWED 
AGAINST UNITED STATES INCOME TAXES.—No cred-
it shall be allowed against United States income 
taxes under section 45U of such Code to any per-
son— 
(A) to whom a credit is allowed against 
taxes imposed by the possession by reason of 
such section, or 
(B) who is eligible for a payment under a 
plan described in paragraph (1)(B). 
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(3) TREATMENT OF PAYMENTS.—For purposes 
of section 1324(b)(2) of title 31, United States 
Code, the payments under this section shall be treat-
ed in the same manner as a refund due from sec-
tions referred to in such section 1324(b)(2). 
SEC. 3. DENIAL OF DEDUCTION FOR OUTSOURCING EX-
PENSES. 
(a) IN GENERAL.—Part IX of subchapter B of chap-
ter 1 of the Internal Revenue Code of 1986 is amended 
by adding at the end the following new section: 
‘‘SEC. 280I. OUTSOURCING EXPENSES. 
‘‘(a) IN GENERAL.—No deduction otherwise allow-
able under this chapter shall be allowed for any specified 
outsourcing expense. 
‘‘(b) SPECIFIED OUTSOURCING EXPENSE.—For pur-
poses of this section— 
‘‘(1) IN
GENERAL.—The term ‘specified out-
sourcing expense’ means— 
‘‘(A) any eligible expense paid or incurred 
by the taxpayer in connection with the elimi-
nation of any business unit of the taxpayer (or 
of any member of any expanded affiliated group 
in which the taxpayer is also a member) located 
within the United States, and 
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‘‘(B) any eligible expense paid or incurred 
by the taxpayer in connection with the estab-
lishment of any business unit of the taxpayer 
(or of any member of any expanded affiliated 
group in which the taxpayer is also a member) 
located outside the United States, 
if such establishment constitutes the relocation of 
business unit so eliminated. For purposes of the pre-
ceding sentence, a relocation shall not be treated as 
failing to occur merely because such elimination oc-
curs in a different taxable year than such establish-
ment. 
‘‘(2) APPLICATION
OF
CERTAIN
DEFINITIONS 
AND RULES.— 
‘‘(A) DEFINITIONS.—For purposes of this 
section, the terms ‘eligible expenses’, ‘business 
unit’, and ‘expanded affiliated group’ shall have 
the respective meanings given such terms by 
section 45U(b). 
‘‘(B) OPERATING EXPENSES NOT TAKEN 
INTO ACCOUNT.—A rule similar to the rule of 
section 45U(b)(6) shall apply for purposes of 
this section. 
‘‘(c) SPECIAL RULES.— 
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