“the amounts included in gross income under sections 951(a), 951A(a), and 78 (and the portion of the deductions allowed under sections 245A(a) (by reason of section 964(e)(4)) and 250(a)(1)(B) by reason of such inclusions), and”
The section adds a new clause (vi) to subparagraph (A) of section 163(j)(8) of the Internal Revenue Code of 1986 bringing into adjusted taxable income the amounts included in gross income under sections 951(a), 951A(a) and 78, together with the part of the deductions allowed under section 245A(a) by reason of section 964(e)(4) and under section 250(a)(1)(B) by reason of those inclusions.
What the document actually says
“the amounts included in gross income under sections 951(a), 951A(a), and 78 (and the portion of the deductions allowed under sections 245A(a) (by reason of section 964(e)(4)) and 250(a)(1)(B) by reason of such inclusions), and”
That sentence, in plain words
Amounts counted as income under three tax rules are named. Part of two deductions tied to them is named too.
What this is about
All of it goes into a tax figure. That figure sets how much interest a business may deduct. The tax code is not indexed here.
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. 70342, 139 Stat. 208 (2025). https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
This page
“Certain foreign income amounts are added to adjusted taxable income,” Provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70342, Sec. 70342. Read the Mandate, https://readthemandate.org/pl-119-21/proposal/sec70342-clause/ (retrieved October 10, 2026).
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