The change applies to foreign firm tax years beginning after December 31, 2025
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.
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