The changes apply to foreign firm tax years beginning after December 31, 2025
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.”
The changes start with foreign firm tax years that begin after December 31, 2025. Older years are left out.
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.
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