The change applies to foreign firm tax years beginning after November 30, 2025
What the document says“The amendments made by this section shall apply to taxable years of specified foreign corporations beginning after November 30, 2025.”
The section applies its amendments to taxable years of specified foreign corporations beginning after November 30, 2025.
What the document actually says“The amendments made by this section shall apply to taxable years of specified foreign corporations beginning after November 30, 2025.”
The changes start with tax years that begin after November 30, 2025. That covers named foreign firms.
Earlier tax years are not touched. The old rules still hold for them. The date is fixed in the law.
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