International Tax Competitiveness Act of 2010 - Amends the Internal Revenue Code to: (1) treat foreign corporations that are managed, directly or indirectly, within the United States as domestic corporations for U.S. tax purposes; (2) make certain royalty income and income from intangibles received from a controlled foreign corporation subject to U.S. taxation; (3) repeal tax rules exempting foreign source income attributable to the active conduct of a foreign trade or business from withholding of tax requirements; and (4) revise the tax treatment of property other than stock (i.e., boot) received in connection with a corporate reorganization to provide that such property shall be treated as a taxable dividend.