If only we didn't buy so much more from Germany, China and Norway than we sell to them (curses), the massive netindebtedness of our economy might actually start to reduce a bit.
America's netindebtedness is a perfectly affordable 65% of GDP, and throughout the past three years of recession and tepid recovery investors have been more than happy to go on lending to the federal government.
This rule can apply where there is a relatively greater amount of indebtedness in the U.S. than offshore, and net interest expense exceeds a specified percentage of adjusted taxable income.
Another provision would disallow a portion of net interest expense to the extent a domestic company is considered as having excess domestic indebtedness.