The first new tax year ends with the first required year
To provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70352, Sec. 70352.
Written by .
The first new tax year ends with the first required year
The document says “shall”Who acts: Secretary of the TreasuryHow: statuteSec. 70352 in the PDF
What the document says
“such corporation's first taxable year beginning after such date shall end at the same time as the first required year (within the meaning of section 898(c)(1) of the Internal Revenue Code of 1986) ending after such date.”
The section provides that a specified foreign corporation as of November 30, 2025 has its first taxable year beginning after that date end at the same time as the first required year ending after that date. Where the change forces a new taxable year, it is treated as initiated by the corporation and made with the Secretary's consent, and the Secretary must issue guidance for splitting foreign taxes paid or accrued in that year and the next between them.
What the document actually says
“such corporation's first taxable year beginning after such date shall end at the same time as the first required year (within the meaning of section 898(c)(1) of the Internal Revenue Code of 1986) ending after such date.”
That sentence, in plain words
The firm's first new tax year ends at a set point. That point is the first required year ending after the same date.
What this is about
A required year is fixed by the tax code. The firm counts as having asked for the change. The Secretary counts as having agreed.
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. 70352, 139 Stat. 208 (2025). https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
This page
“The first new tax year ends with the first required year,” Provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70352, Sec. 70352. Read the Mandate, https://readthemandate.org/pl-119-21/proposal/sec70352-transition/ (retrieved October 10, 2026).
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