One change runs from June 16, 2025 and the other from tax year 2026
To provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70322, Sec. 70322.
Written by .
One change runs from June 16, 2025 and the other from tax year 2026
The document says “shall apply”Who acts: Secretary of the TreasuryHow: statuteSec. 70322 in the PDF
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.”
That sentence, in plain words
The first change reaches sales made after June 16, 2025. A deemed sale counts as a sale here.
What this is about
The second change works by tax year. It starts with years that begin after December 31, 2025. Both dates are fixed in the law.
No action is recorded against this proposal. That is not evidence that none has been taken, and nobody has yet read it against the record. See what the tracker does not yet cover.
Provide for reconciliation pursuant to title II of H. Con. Res. 14, Public Law 119-21, sec. 70322, 139 Stat. 204 (2025). https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
This page
“One change runs from June 16, 2025 and the other from tax year 2026,” Provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70322, Sec. 70322. Read the Mandate, https://readthemandate.org/pl-119-21/proposal/sec70322-effective-dates/ (retrieved October 10, 2026).
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