The section 951A rules are matched to the new pro rata approach
What the document says“in paragraph (2), by striking "the last day in the taxable year of such foreign corporation on which such foreign corporation is a controlled foreign corporation" and inserting "any day in such taxable year".”
The section strikes from paragraphs (1)(A) and (1)(B) of section 951A(b) of the Internal Revenue Code of 1986 the words tying tested income to the foreign corporation's year ending in or with the shareholder's year, and amends section 951A(c) so that paragraph (1) points to section 951(a)(3) and paragraph (2) reads any day in such taxable year.
What the document actually says“in paragraph (2), by striking "the last day in the taxable year of such foreign corporation on which such foreign corporation is a controlled foreign corporation" and inserting "any day in such taxable year".”
A long phrase is taken out of a tax rule. The words any day in such taxable year are put in.
The old phrase named only the last qualifying day. The new one reaches any day. A matching change is made in the rule before it.
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