Sec. 4. Denial of certain deductions and accounting methods for outsourcing employers
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Part IX of subchapter B of chapter 1 of the Internal Revenue Code of 1986, as amended by section 3, is amended by adding at the end the following new section: During the disallowance period, an applicable taxpayer— may not use the method provided in section 472(b) in inventorying goods, may not use the lower of cost or market method of determining inventories for purposes of determining income, and shall not be allowed any deduction under section 163 for interest paid or accrued on indebtedness. For purposes of subsection (a), the term applicable taxpayer means a taxpayer which— during the taxable year, has served written notice under subsection
(a)of section 3 of the Worker Adjustment and Retraining Notification Act which includes an outsourcing statement described in subsection
(e)of such section, and 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. For purposes of subsection (a), the disallowance period is the period of 3 taxable years after the taxable year in which the statements described in subsection (b)(2) are required to be served. 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. The Secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section. . The table of sections for part IX of subchapter B of chapter 1 of the Internal 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. . The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.