The changes apply to foreign firm tax years beginning after December 31, 2025
To provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70353, Sec. 70353.
Written by .
The changes apply to foreign firm tax years beginning after December 31, 2025
The document says “shall apply”Who acts: Secretary of the TreasuryHow: statuteSec. 70353 in the PDF
What the document says
“The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025.”
The section applies its amendments to taxable years of foreign corporations beginning after December 31, 2025. Except as the Secretary provides, the effective date of any amendment to the Internal Revenue Code of 1986 is applied by reading references to United States shareholders and controlled foreign corporations as including the new terms. The amendments are not to be read as creating any inference about how the Code applied to earlier years.
What the document actually says
“The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025.”
That sentence, in plain words
The changes start with foreign firm tax years that begin after December 31, 2025. Older years are left out.
What this is about
Earlier tax years are not touched. The law says no view is taken on them. The new terms are read into other effective date rules.
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. 70353, 139 Stat. 209 (2025). https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
This page
“The changes apply to foreign firm tax years beginning after December 31, 2025,” Provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70353, Sec. 70353. Read the Mandate, https://readthemandate.org/pl-119-21/proposal/sec70353-effective-date/ (retrieved October 10, 2026).
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