Statutory Notes and Related Subsidiaries

Effective Date

Pub. L. 119–21, title VII, § 70353(d), July 4, 2025, 139 Stat. 210, provided that: “The amendments made by this section [enacting this section and amending section 958 of this title] shall apply to taxable years of foreign corporations beginning after December 31, 2025.”

Construction

Pub. L. 119–21, title VII, § 70353(f), July 4, 2025, 139 Stat. 210, provided that: “The amendments made by this section [enacting this section and amending section 958 of this title] shall not be construed to create any inference with respect to the proper application of any provision of the Internal Revenue Code of 1986 with respect to taxable years beginning before the taxable years to which such amendments apply.”

Special Rule

Pub. L. 119–21, title VII, § 70353(e), July 4, 2025, 139 Stat. 210, provided that:

“(1)

In general.—

Except to the extent provided by the Secretary of the Treasury (or the Secretary’s delegate), the effective date of any amendment to the Internal Revenue Code of 1986 shall be applied by treating references to United States shareholders as including references to foreign controlled United States shareholders, and by treating references to controlled foreign corporations as including references to foreign controlled foreign corporations.

“(2)

Definitions.—

Any term used in paragraph (1) which is used in subpart F of part III of subchapter N of chapter 1 of the Internal Revenue Code of 1986 (as amended by this section) shall have the meaning given such term in such subpart.”