Instructions: In this task, you are given a summary for US Congressional and California state bill, your task is to generate a Title for this bill. The preferred titles are under forty words and mention the purpose of the bill.
Input: Corporate Inverters Earnings Stripping Reform Act of 2014 - Amends the Internal Revenue Code to impose limitations on the tax deduction for interest paid by corporations which are designated as applicable entities (i.e., members of an expanded affiliated group which includes a surrogate foreign corporation which is not treated as a domestic corporation). Prohibits such an entity from claiming a tax deduction for interest that exceeds 25% of its adjusted taxable income and from carrying forward interest which is paid or accrued during the first year in which such entity becomes an applicable entity. Requires an applicable entity to file an annual application for an approval agreement (i.e., a prefiling, advance pricing, or other agreement involving a related-party transaction) with the Internal Revenue Service (IRS) during the 10-year period after it becomes an applicable entity.
Output:
Corporate Inverters Earnings Stripping Reform Act of 2014