I 
116TH CONGRESS 
2D SESSION 
H. R. 6121 
To provide incentives for businesses to keep jobs in America, and for other 
purposes. 
IN THE HOUSE OF REPRESENTATIVES 
MARCH 5, 2020 
Mr. POCAN (for himself, Ms. KAPTUR, Ms. LEE of California, Ms. NORTON, 
and Mr. RYAN) introduced the following bill; which was referred to the 
Committee on Ways and Means, and in addition to the Committees on 
Education and Labor, Armed Services, and Oversight and Reform, for a 
period to be subsequently determined by the Speaker, in each case for 
consideration of such provisions as fall within the jurisdiction of the com-
mittee concerned 
A BILL 
To provide incentives for businesses to keep jobs in America, 
and for other purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘End Outsourcing Act’’. 
SEC. 2. OUTSOURCING STATEMENT IN WORKER ADJUST-
MENT AND RETRAINING NOTICE. 
(a) OUTSOURCING STATEMENT.—Section 3 of the 
Worker Adjustment and Retraining Notification Act (29 
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U.S.C. 2102) is amended by adding at the end the fol-
lowing: 
‘‘(e) OUTSOURCING STATEMENT.— 
‘‘(1) IN GENERAL.—For purposes of subsection 
(a), the employer shall include an outsourcing state-
ment in the notice described in that subsection. The 
outsourcing statement shall specify whether part or 
all of the positions held by affected employees cov-
ered by subsection (a) will be moved to a country 
outside the United States, regardless of whether the 
positions are moved within the business enterprise 
involved or to another business enterprise. The em-
ployer shall make the determination of whether the 
positions are being so moved in accordance with reg-
ulations issued by the Secretary. The employer shall 
serve the notice as required under subsection (a) and 
submit the notice to the Secretary of Labor. 
‘‘(2) LIST.—Not less often than annually, the 
Secretary shall publish and make available on the 
website of the Department of Labor, a list including 
each employer who— 
‘‘(A) has included an outsourcing state-
ment in a notice under paragraph (1); or 
‘‘(B) has incurred liability under section 5, 
in part or in whole, because the employer or-
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dered a plant closing or mass layoff without 
having served a notice that is required, under 
this section, to include an outsourcing state-
ment.’’. 
(b) IMPLEMENTATION REPORT.—The Worker Ad-
justment and Retraining Notification Act is amended by 
inserting after section 10 (29 U.S.C. 2109) the following: 
‘‘SEC. 10A. IMPLEMENTATION STUDY. 
‘‘(a) STUDY.—The Comptroller General of the United 
States shall conduct a study of the implementation of sec-
tion 3(e) of the Worker Adjustment and Retraining Notifi-
cation Act (29 U.S.C. 2102(e)) by the Department of 
Labor. 
‘‘(b) REPORT.—Not later than 3 years after the date 
of enactment of this section, the Comptroller General shall 
submit to the appropriate committees of Congress a report 
containing the results of the study.’’. 
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: 
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‘‘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 
‘‘(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 
the business unit so eliminated. For purposes of the 
preceding sentence, a relocation shall not be treated 
as failing to occur merely because such elimination 
occurs in a different taxable year than such estab-
lishment. 
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‘‘(2) ELIGIBLE EXPENSES.—The term ‘eligible 
expenses’ means— 
‘‘(A) any amount for which a deduction is 
allowed to the taxpayer under section 162, and 
‘‘(B) permit and license fees, lease broker-
age fees, equipment installation costs, and, to 
the extent provided by the Secretary, other 
similar expenses. 
Such term does not include any compensation which 
is paid or incurred in connection with severance 
from employment and, to the extent provided by the 
Secretary, any similar amount. 
‘‘(3) BUSINESS UNIT.—The term ‘business unit’ 
means— 
‘‘(A) any trade or business, and 
‘‘(B) any line of business, or functional 
unit, which is part of any trade or business. 
‘‘(4) EXPANDED
AFFILIATED
GROUP.—The 
term ‘expanded affiliated group’ means an affiliated 
group as defined in section 1504(a), determined 
without regard to section 1504(b)(3) and by sub-
stituting ‘more than 50 percent’ for ‘at least 80 per-
cent’ each place it appears in section 1504(a). A 
partnership or any other entity (other than a cor-
poration) shall be treated as a member of an ex-
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panded affiliated group if such entity is controlled 
(within the meaning of section 954(d)(3)) by mem-
bers of such group (including any entity treated as 
a member of such group by reason of this para-
graph). 
‘‘(5) OPERATING EXPENSES NOT TAKEN INTO 
ACCOUNT.—Any amount paid or incurred in connec-
tion with the ongoing operation of a business unit 
shall not be treated as an amount paid or incurred 
in connection with the establishment or elimination 
of such business unit. 
‘‘(c) SPECIAL RULES.— 
‘‘(1) APPLICATION
TO
DEDUCTIONS
FOR
DE-
PRECIATION
AND
AMORTIZATION.—In the case of 
any portion of a specified outsourcing expense which 
is not deductible in the taxable year in which paid 
or incurred, such portion shall neither be chargeable 
to capital account nor amortizable. 
‘‘(2) POSSESSIONS TREATED AS PART OF THE 
UNITED STATES.—For purposes of this section, the 
term ‘United States’ shall be treated as including 
each possession of the United States (including the 
Commonwealth of Puerto Rico and the Common-
wealth of the Northern Mariana Islands). 
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‘‘(d) REGULATIONS.—The Secretary shall prescribe 
such regulations or other guidance as may be necessary 
or appropriate to carry out the purposes of this section, 
including regulations which provide (or create a rebuttable 
presumption) that certain establishments of business units 
outside the United States will be treated as relocations 
(based on timing or such other factors as the Secretary 
may provide) of business units eliminated within the 
United States.’’. 
(b) LIMITATION ON SUBPART F INCOME OF CON-
TROLLED FOREIGN CORPORATIONS DETERMINED WITH-
OUT REGARD TO SPECIFIED OUTSOURCING EXPENSES.— 
Subsection (c) of section 952 of such Code is amended 
by adding at the end the following new paragraph: 
‘‘(4) EARNINGS
AND
PROFITS
DETERMINED 
WITHOUT REGARD TO SPECIFIED OUTSOURCING EX-
PENSES.—For purposes of this subsection, earnings 
and profits of any controlled foreign corporation 
shall be determined without regard to any specified 
outsourcing 
expense 
(as 
defined 
in 
section 
280I(b)).’’. 
(c) CLERICAL AMENDMENT.—The table of sections 
for part IX of subchapter B of chapter 1 of such Code 
is amended by adding at the end the following new item: 
‘‘Sec. 280I. Outsourcing expenses.’’. 
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(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. 
SEC. 4. DENIAL OF CERTAIN DEDUCTIONS AND ACCOUNT-
ING METHODS FOR OUTSOURCING EMPLOY-
ERS. 
(a) IN GENERAL.—Part IX of subchapter B of chap-
ter 1 of the Internal Revenue Code of 1986, as amended 
by section 3, is amended by adding at the end the fol-
lowing new section: 
‘‘SEC. 280J. LIMITATIONS FOR OUTSOURCING EMPLOYERS. 
‘‘(a) IN GENERAL.—During the disallowance period, 
an applicable taxpayer— 
‘‘(1) may not use the method provided in sec-
tion 472(b) in inventorying goods, 
‘‘(2) may not use the lower of cost or market 
method of determining inventories for purposes of 
determining income, and 
‘‘(3) shall not be allowed any deduction under 
section 163 for interest paid or accrued on indebted-
ness. 
‘‘(b) APPLICABLE TAXPAYER.—For purposes of sub-
section (a), the term ‘applicable taxpayer’ means a tax-
payer which— 
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‘‘(1) during the taxable year, has served written 
notice under subsection (a) of section 3 of the Work-
er Adjustment and Retraining Notification Act 
which includes an outsourcing statement described 
in subsection (e) of such section, and 
‘‘(2) the cumulative employment loss (excluding 
any part-time employees) for positions at facilities 
owned by such taxpayer which will be moved to a 
country outside of the United States, as determined 
pursuant to any outsourcing statements served by 
such taxpayer during such taxable year, exceeds 50 
employees. 
‘‘(c) DISALLOWANCE PERIOD.—For purposes of sub-
section (a), the disallowance period is the period of 3 tax-
able years after the taxable year in which the statements 
described in subsection (b)(2) are required to be served. 
‘‘(d) EXPANDED AFFILIATED GROUP TREATED AS 
SINGLE TAXPAYER.—For purposes of this section, the 
members of an expanded affiliated group (as defined in 
section 280I(b)(4)) shall be treated as a single taxpayer. 
‘‘(e) 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) CLERICAL AMENDMENT.—The table of sections 
for part IX of subchapter B of chapter 1 of the Internal 
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Revenue Code of 1986, as amended by section 3, is 
amended by adding at the end the following new item: 
‘‘Sec. 280J. Limitations for outsourcing employers.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
SEC. 5. CURRENT YEAR INCLUSION OF NET CFC TESTED IN-
COME. 
(a) REPEAL OF TAX-FREE DEEMED RETURN ON IN-
VESTMENTS.— 
(1) IN GENERAL.—Section 951A(a) of the In-
ternal Revenue Code of 1986 is amended by striking 
‘‘global intangible low-taxed income’’ and inserting 
‘‘net CFC tested income’’. 
(2) CONFORMING AMENDMENTS.— 
(A) Section 951A of such Code is amended 
by striking subsections (b) and (d). 
(B) Section 951A(e)(1) of such Code is 
amended 
by 
striking 
‘‘subsections 
(b), 
(c)(1)(A), and’’ and inserting ‘‘subsections 
(c)(1)(A) and’’. 
(C) Section 951A(f) of such Code is 
amended to read as follows: 
‘‘(f) TREATMENT AS SUBPART F INCOME FOR CER-
TAIN PURPOSES.— 
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‘‘(1) IN GENERAL.—Except as provided in para-
graph (2), any net CFC tested income included in 
gross income under subsection (a) shall be treated in 
the same manner as an amount included under sec-
tion 951(a)(1)(A) for purposes of applying sections 
168(h)(2)(B), 535(b)(10), 851(b), 904(h)(1), 959, 
961, 962, 993(a)(1)(E), 996(f)(1), 1248(b)(1), 
1248(d)(1), 
6501(e)(1)(C), 
6654(d)(2)(D), 
and 
6655(e)(4). 
‘‘(2) EXCEPTION.—The Secretary shall provide 
rules for the application of paragraph (1) to other 
provisions of this title in any case in which the de-
termination of subpart F income is required to be 
made at the level of the controlled foreign corpora-
tion.’’. 
(D) Section 960(d)(2)(A) of such Code is 
amended by striking ‘‘global intangible low- 
taxed income (as defined in section 951A(b))’’ 
and inserting ‘‘net CFC tested income (as de-
fined in section 951A(c))’’. 
(b) REPEAL OF REDUCED RATE OF TAX ON NET 
CFC TESTED INCOME.— 
(1) IN GENERAL.—Part VIII of subchapter B 
of chapter 1 of such Code is amended by striking 
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(VI), respectively, and by inserting after subclause (III) 
the following new subclause: 
‘‘(IV) any item of income subject 
to an effective rate of income tax im-
posed by a foreign country greater 
than the maximum rate of tax speci-
fied in section 11,’’. 
(d) REPEAL OF EXCLUSION OF FOREIGN OIL AND 
GAS EXTRACTION INCOME FROM THE DETERMINATION 
OF TESTED INCOME.—Section 951A(c)(2)(A)(i) of such 
Code, as amended by subsection (c) is amended— 
(1) by adding ‘‘and’’ at the end of subclause 
(IV); 
(2) by striking ‘‘and’’ at the end of subclause 
(V) and inserting ‘‘over’’; and 
(3) by striking subclause (VI). 
(e) INCREASE IN DEEMED PAID CREDIT FOR TAXES 
PROPERLY ATTRIBUTABLE TO TESTED INCOME.— 
(1) IN GENERAL.—Section 960(d) of such Code 
is amended by striking ‘‘80 percent of’’. 
(2) CONFORMING AMENDMENT.—Section 78 of 
such Code is amended by striking ‘‘(determined 
without regard to the phrase ‘‘80 percent of’’ in sub-
section (d)(1) thereof)’’. 
(f) EFFECTIVE DATE.— 
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(1) IN
GENERAL.—Except as otherwise pro-
vided in this subsection, the amendments made by 
this section shall apply to taxable years of foreign 
corporations beginning after December 31, 2019, 
and to taxable years of United States shareholders 
in which or with which such taxable years of foreign 
corporations end. 
(2) REPEAL OF REDUCED RATE OF TAX; IN-
CREASE
IN
DEEMED
PAID
CREDIT.—The amend-
ments made by subsections (b) and (e) shall apply 
to taxable years beginning after December 31, 2019. 
SEC. 6. RECAPTURE OF CREDITS FOR OUTSOURCING EM-
PLOYERS. 
(a) IN GENERAL.—Part IV of subchapter A of chap-
ter 1 of the Internal Revenue Code of 1986 is amended 
by adding at the end the following new subpart: 
‘‘Subpart H—Recapture of Credits for Outsourcing 
Employers 
‘‘Sec. 54. Recapture of credits for outsourcing employers. 
‘‘SEC. 54. RECAPTURE OF CREDITS FOR OUTSOURCING EM-
PLOYERS. 
‘‘(a) IN GENERAL.—Pursuant to regulations pre-
scribed by the Secretary, in the case of a taxpayer which 
owns a facility for which there is an outsourcing event dur-
ing the taxable year, the tax under this chapter for such 
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taxable year shall be increased by the amount equal to 
the sum of— 
‘‘(1) any credits allowed under this chapter re-
lating to expenses for design, construction, oper-
ation, or maintenance of such facility during the 5 
taxable years preceding such taxable year, and 
‘‘(2) any grants provided by the Secretary in 
lieu of credits described in paragraph (1) during the 
5 taxable years preceding such taxable year. 
‘‘(b) OUTSOURCING EVENT.—For purposes of sub-
section (a), the term ‘outsourcing event’ means a plant 
closing or mass layoff (as described in section 2(a) of the 
Worker Adjustment and Retraining Notification Act) in 
which the employment loss (excluding any part-time em-
ployees) for positions which will be moved to a country 
outside of the United States, as determined pursuant to 
the outsourcing statement (as described in paragraph (1) 
of such section 3(e) of such Act) served by the taxpayer 
during the taxable year, exceeds 50 employees. 
‘‘(c) EXPANDED AFFILIATED GROUP TREATED AS 
SINGLE TAXPAYER.—For purposes of this section, the 
members of an expanded affiliated group (as defined in 
section 280I(b)(4)) shall be treated as a single taxpayer.’’. 
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(b) CLERICAL AMENDMENT.—The table of subparts 
for part IV of subchapter A of chapter 1 of such Code 
is amended by adding at the end the following new item: 
‘‘SUBPART H. RECAPTURE OF CREDITS FOR OUTSOURCING EMPLOYERS’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
SEC. 7. CREDIT FOR INSOURCING EXPENSES. 
(a) IN GENERAL.—Subpart D of part IV of sub-
chapter A of chapter 1 of the Internal Revenue Code of 
1986 is amended by adding at the end the following new 
section: 
‘‘SEC. 45T. CREDIT FOR INSOURCING EXPENSES. 
‘‘(a) IN GENERAL.—For purposes of section 38, the 
insourcing expenses credit for any taxable year is an 
amount equal to 20 percent of the eligible insourcing ex-
penses of the taxpayer which are taken into account in 
such taxable year under subsection (d). 
‘‘(b) ELIGIBLE INSOURCING EXPENSES.—For pur-
poses of this section— 
‘‘(1) 
IN
GENERAL.—The 
term 
‘eligible 
insourcing expenses’ means— 
‘‘(A) eligible expenses paid or incurred by 
the taxpayer in connection with the elimination 
of any business unit of the taxpayer (or of any 
member of any expanded affiliated group in 
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which the taxpayer is also a member) located 
outside the United States, and 
‘‘(B) eligible expenses paid or incurred by 
the taxpayer in connection with the establish-
ment 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— 
‘‘(i) a HUBZone (as defined in sec-
tion 3(p)(2) of the Small Business Act (15 
U.S.C. 632(p)(2))), or 
‘‘(ii) a low-income community (as de-
scribed in section 45D(e)), 
if such establishment constitutes the relocation of 
the business unit so eliminated. For purposes of the 
preceding sentence, a relocation shall not be treated 
as failing to occur merely because such elimination 
occurs in a different taxable year than such estab-
lishment. 
‘‘(2) ELIGIBLE EXPENSES.—The term ‘eligible 
expenses’ means— 
‘‘(A) any amount for which a deduction is 
allowed to the taxpayer under section 162, and 
‘‘(B) permit and license fees, lease broker-
age fees, equipment installation costs, and, to 
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the extent provided by the Secretary, other 
similar expenses. 
Such term does not include any compensation which 
is paid or incurred in connection with severance 
from employment and, to the extent provided by the 
Secretary, any similar amount. 
‘‘(3) BUSINESS UNIT.—The term ‘business unit’ 
means— 
‘‘(A) any trade or business, and 
‘‘(B) any line of business, or functional 
unit, which is part of any trade or business. 
‘‘(4) EXPANDED
AFFILIATED
GROUP.—The 
term ‘expanded affiliated group’ means an affiliated 
group as defined in section 1504(a), determined 
without regard to section 1504(b)(3) and by sub-
stituting ‘more than 50 percent’ for ‘at least 80 per-
cent’ each place it appears in section 1504(a). A 
partnership or any other entity (other than a cor-
poration) shall be treated as a member of an ex-
panded affiliated group if such entity is controlled 
(within the meaning of section 954(d)(3)) by mem-
bers of such group (including any entity treated as 
a member of such group by reason of this para-
graph). 
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‘‘(5) EXPENSES
MUST
BE
PURSUANT
TO 
INSOURCING PLAN.—Amounts shall be taken into ac-
count under paragraph (1) only to the extent that 
such amounts are paid or incurred pursuant to a 
written plan to carry out the relocation described in 
paragraph (1). 
‘‘(6) OPERATING EXPENSES NOT TAKEN INTO 
ACCOUNT.—Any amount paid or incurred in connec-
tion with the on-going operation of a business unit 
shall not be treated as an amount paid or incurred 
in connection with the establishment or elimination 
of such business unit. 
‘‘(c) INCREASED DOMESTIC EMPLOYMENT REQUIRE-
MENT.—No credit shall be allowed under this section un-
less the number of full-time equivalent employees of the 
taxpayer for the taxable year for which the credit is 
claimed exceeds the number of full-time equivalent em-
ployees of the taxpayer for the last taxable year ending 
before the first taxable year in which such eligible 
insourcing expenses were paid or incurred. For purposes 
of this subsection, full-time equivalent employees has the 
meaning given such term under section 45R(d) (and the 
applicable rules of section 45R(e)). All employers treated 
as a single employer under subsection (b), (c), (m), or (o) 
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of section 414 shall be treated as a single employer for 
purposes of this subsection. 
‘‘(d) CREDIT ALLOWED UPON COMPLETION
OF 
INSOURCING PLAN.— 
‘‘(1) IN GENERAL.—Except as provided in para-
graph (2), eligible insourcing expenses shall be taken 
into account under subsection (a) in the taxable year 
during which the plan described in subsection (b)(5) 
has been completed and all eligible insourcing ex-
penses pursuant to such plan have been paid or in-
curred. 
‘‘(2) ELECTION TO APPLY EMPLOYMENT TEST 
AND CLAIM CREDIT IN FIRST FULL TAXABLE YEAR 
AFTER
COMPLETION
OF
PLAN.—If the taxpayer 
elects the application of this paragraph, eligible 
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). 
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‘‘(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.—Subsection (b) of section 38 of such Code is 
amended by striking ‘‘plus’’ at the end of paragraph (31), 
by striking the period at the end of paragraph (32) and 
inserting ‘‘, plus’’, and by adding at the end the following 
new paragraph: 
‘‘(33) the insourcing expenses credit determined 
under section 45T(a).’’. 
(c) CLERICAL AMENDMENT.—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 fol-
lowing new item: 
‘‘Sec. 45T. 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 each possession of the United 
States with a mirror code tax system in an 
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amount equal to the loss to that possession by 
reason of section 45T of the Internal Revenue 
Code of 1986. Such amount shall be determined 
by the Secretary of the Treasury based on in-
formation provided by the government of the re-
spective possession. 
(B) OTHER POSSESSIONS.—The Secretary 
of the Treasury shall make annual payments to 
each possession of the United States which does 
not have a mirror code tax system in an 
amount estimated by the Secretary of the 
Treasury as being equal to the aggregate bene-
fits that would have been provided to residents 
of such possession by reason of section 45T of 
such Code if a mirror code tax system had been 
in effect in such possession. The preceding sen-
tence shall not apply with respect to any posses-
sion 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 pay-
ment to the residents of such possession. 
(2) COORDINATION
WITH
CREDIT
ALLOWED 
AGAINST UNITED STATES INCOME TAXES.—No cred-
it shall be allowed against United States income 
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taxes under section 45T 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). 
(3) DEFINITIONS AND SPECIAL RULES.— 
(A) 
POSSESSIONS
OF
THE
UNITED 
STATES.—For purposes of this section, the 
term ‘‘possession of the United States’’ includes 
the Commonwealth of Puerto Rico and the 
Commonwealth of the Northern Mariana Is-
lands. 
(B) MIRROR CODE TAX SYSTEM.—For pur-
poses of this section, the term ‘‘mirror code tax 
system’’ means, with respect to any possession 
of the United States, the income tax system of 
such possession if the income tax liability of the 
residents of such possession under such system 
is determined by reference to the income tax 
laws of the United States as if such possession 
were the United States. 
(C) TREATMENT OF PAYMENTS.—For pur-
poses of section 1324(b)(2) of title 31, United 
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States Code, the payments under this section 
shall be treated in the same manner as a refund 
due from sections referred to in such section 
1324(b)(2). 
SEC. 8. AUTHORITY FOR FEDERAL CONTRACTING OFFI-
CERS TO TAKE THE OUTSOURCING OF JOBS 
FROM THE UNITED STATES INTO ACCOUNT 
IN AWARDING CONTRACTS. 
(a) DEPARTMENT
OF
DEFENSE
AND
RELATED 
AGENCY CONTRACTS.— 
(1) CONSIDERATION OF OUTSOURCING.— 
(A) IN
GENERAL.—Chapter 137 of title 
10, United States Code, is amended by insert-
ing after section 2327 the following new sec-
tion: 
‘‘§ 2327a. Contracts: consideration of outsourcing of 
jobs 
‘‘(a) DISCLOSURE OF OUTSOURCING OF JOBS.— 
‘‘(1) IN
GENERAL.—The head of an agency 
shall require a contractor that submits a bid or pro-
posal in response to a solicitation issued by the 
agency to disclose in that bid or proposal if the con-
tractor, or a subsidiary of the contractor, owns a fa-
cility for which there is an outsourcing event during 
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