The change applies to foreign firm tax years beginning after December 31, 2025
To provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70351, Sec. 70351.
Written by .
The change applies to foreign firm tax years beginning after December 31, 2025
The document says “shall apply”Who acts: Secretary of the TreasuryHow: statuteSec. 70351 in the PDF
What the document says
“The amendment made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025.”
The section applies its amendment to taxable years of foreign corporations beginning after December 31, 2025.
What the document actually says
“The amendment made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025.”
That sentence, in plain words
The change starts with foreign firm tax years that begin after December 31, 2025.
What this is about
Earlier tax years are not touched. The old rule still holds for them. The date is 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. 70351, 139 Stat. 208 (2025). https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
This page
“The change applies to foreign firm tax years beginning after December 31, 2025,” Provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70351, Sec. 70351. Read the Mandate, https://readthemandate.org/pl-119-21/proposal/sec70351-effective-date/ (retrieved October 10, 2026).
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