One change runs from June 16, 2025 and the other from tax year 2026
What the document says“The amendments made by this subsection shall apply to sales or other dispositions (including pursuant to deemed sales or other deemed dispositions or a transaction subject to section 367(d) of the Internal Revenue Code of 1986) occurring after June 16, 2025.”
The section applies the change on sales and dispositions to those occurring after June 16, 2025, and applies the change on expense apportionment to taxable years beginning after December 31, 2025.
What the document actually says“The amendments made by this subsection shall apply to sales or other dispositions (including pursuant to deemed sales or other deemed dispositions or a transaction subject to section 367(d) of the Internal Revenue Code of 1986) occurring after June 16, 2025.”
The first change reaches sales made after June 16, 2025. A deemed sale counts as a sale here.
The second change works by tax year. It starts with years that begin after December 31, 2025. Both dates are fixed in the law.
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