One change starts with tax year 2026 and the other from June 28, 2025
What the document says“The amendments made by subsection (a) shall apply to taxable years beginning after December 31, 2025.”
The section applies the change in percentage to taxable years beginning after December 31, 2025, and applies the disallowance to foreign income taxes paid, accrued or deemed paid on an amount excluded under section 959(a) because of an inclusion under section 951A(a) after June 28, 2025.
What the document actually says“The amendments made by subsection (a) shall apply to taxable years beginning after December 31, 2025.”
The change in the figure starts with tax years that begin after December 31, 2025.
The other change runs from June 28, 2025. It is tied to when the tax is paid. Both dates are fixed in the law.
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