US SB409

Requires U.S. shareholders to include net controlled foreign corporation (CFC) tested income in current year taxable income, calculated on a country-by-country basis rather than allowing tax-free deemed returns on overseas investments

Repeals Section 250 deductions that provided reduced tax rates on global intangible low-taxed income (GILTI) and foreign-derived intangible income, and increases the deemed paid foreign tax credit from 80% to 100%

Limits interest deductions for domestic corporations in international financial reporting groups with over $100 million in average annual gross receipts to 110% of their allocable share of the group's net interest expense based on EBITDA ratios

Expands treatment of "inverted corporations" as domestic corporations by lowering the ownership threshold from 80% to 50% and targeting companies with management/control primarily in the U.S. after December 22, 2017

Treats foreign corporations as domestic corporations for income tax purposes if management and control occurs primarily within the United States and the corporation has assets of $50 million or more or publicly traded stock