The National Association of Manufacturers has just sent a “Key Vote” letter to the U.S. House, expressing the NAM’s strong opposition to H.R. 5893, the Investing in American Jobs and Closing Tax Loopholes Act of 2010.

The full letter is available here. The gist:

An estimated 22 million people in the United States—more than 19 percent of the private sector workforce and 53 percent of all manufacturing employees—are employed by companies with operations overseas. Manufacturers feel strongly that imposing $11.5 billion in tax increases on these companies as proposed by H.R. 5893 will jeopardize the jobs of American manufacturing employees and stifle our fragile economy.

Many of the tax increases proposed in H.R. 5893, which are mischaracterized as closing tax loopholes, actually represent significant changes to the pro-growth tax policy supported by Congress and the Administration. For example, the proposed anti-competitive limitation on the use of Sec. 956 loans removes a greatly needed source of U.S. cash for worldwide American companies – a source that Treasury and the Internal Revenue Service (IRS) sought to facilitate in guidance issued as recently as last December. As we continue to work through one of the greatest credit crunches in U.S. history, taking away a source of cash for U.S. companies to grow, build and create jobs puts our fragile recovery at risk.

We are disappointed that many of the bill’s proposed tax increases have not been adequately scrutinized during congressional hearings. In many cases, taxpayers have relied on these longstanding tax provisions in structuring their businesses. Changing the rules without fair and adequate hearings will cost in terms of jobs, investment and manufacturers’ ability to compete overseas.

Manufacturers believe strongly that changes to our international tax laws should be considered in the broader context of tax reform that makes the United States more competitive – not as “pay fors” for unrelated policy initiatives. Moreover, targeting some international tax law changes in advance of the tax reform debate would make the goal of pro-growth, pro-competitiveness reform that much more difficult, if not impossible, to achieve.

The bill has some good provisions, such as extending the Build America Bonds authority and lifting the state volume cap for private activity bonds for water and waste water infrastructure. But the major impact of the bill is to raise taxes on companies that create wealth and jobs in the United States, in the process making the U.S. a less attractive, less competitive place to do business.

The NAM uses “Key Vote” letters to inform members of Congress that the pending votes will be taken into account when assessing a member’s record on manufacturing-related issues.