The criticism boils down to this: It isn't the tax code that created the offshore outsourcing industry over the last decade; it's the low cost of highly skilled labor.

President Obama didn't address the wage gap today, but he is arguing that the tax code has played a contributing role in the growth of offshoring, and that includes high-skilled outsourcing.

In his remarks, he cited a major Indian IT outsourcing center, Bangalore, as one of the places that has benefited from tax loopholes. The U.S. has developed "a tax code that says you should pay lower taxes if you create a job in Bangalore, India, than if you create one in Buffalo, New York," Obama said.

These tax loopholes give companies that create jobs overseas the ability to take deductions on expenses "when they do not pay any American taxes on their profits," he said.

The proposed tax changes, which must be approved by Congress, may affect IT vendors that run subsidiaries overseas by denying deductions for offshore payments on things like payroll expenses, said Alan Appel, a tax attorney at Bryan Cave LLP in New York.