Comment on FR Doc # 2012-11148

I believe this to be a necessary and prudent action. The proposed rule states that an inverted domestic corporation is “one that used to be incorporated in the United States, or used to be a partnership in the United States, but now is incorporated in a foreign country, or is a subsidiary whose parent corporation is incorporated in a foreign country.” First, at a time where millions of people cannot find well-compensating jobs, unemployment is at near-record highs, youth unemployment in the double digits, and job growth is slow, it seems a contradiction of American values to allow those corporations that have moved abroad to profit while not providing jobs or profits to American workers. Second, for a company to have “turned their back” on the United States and to have likely downsized (eliminated American personnel) in order to go abroad to become an “inverted domestic corporation” and still wish to take government dollars seems a foolhardy exercise, and it is fair for the government to take this action. The Buy American Act of 1933 seems to have created precedent to prefer American-made products relative to non-domestically produced ones. Thus, this act seems to properly favor domestic firms over foreign ones. Further, the rule states that small businesses and domestic entities won't be impacted by this rule. I see few downsides to this rule. However, my one concern is the lack of possible leeway needed for possible purchases. There may not be any domestic firms producing a certain part, for instance, and that could conceivably detract from the DoD or NASA if they cannot buy it from the inverted corporation. While leaving the door open to inverted companies seems unfair, perhaps a conditional allowance for contracts to be allowed with these firms only if there are no domestic counterparts for it would be wise.