This part renames two tax terms across the code. Global intangible low-taxed income becomes net CFC tested income. Foreign-derived intangible income becomes foreign-derived deduction eligible income. It also repeals a tax free deemed return on foreign investment.
“Section 951A(a) is amended by striking "global intangible low-taxed income" and inserting "net CFC tested income".”
The section strikes the words global intangible low-taxed income in section 951A(a) of the Internal Revenue Code of 1986 and inserts net CFC tested income, and carries the new term through section 250, the redesignated subsections of section 951A, section 960(d)(2), the headings of sections 250 and 951A, and the related table of sections items.
What the document actually says
“Section 951A(a) is amended by striking "global intangible low-taxed income" and inserting "net CFC tested income".”
That sentence, in plain words
One term is taken out of a tax rule. A new term is put in its place.
What this is about
The old term ran to five words. The new one is net CFC tested income. The change is carried through the whole tax code.
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.
“Section 951A, as amended by the preceding provisions of this Act, is amended by striking subsections (b) and (d) and by redesignating subsections (c), (e), and (f) as subsections (b), (c), and (d), respectively.”
The section strikes subsections (b) and (d) of section 951A of the Internal Revenue Code of 1986 and renumbers subsections (c), (e) and (f) as (b), (c) and (d). Those provisions are not indexed here, so what they said cannot be checked against anything on this site.
What the document actually says
“Section 951A, as amended by the preceding provisions of this Act, is amended by striking subsections (b) and (d) and by redesignating subsections (c), (e), and (f) as subsections (b), (c), and (d), respectively.”
That sentence, in plain words
Two subsections are taken out of a tax rule. Three others are renumbered to fill the gap.
What this is about
The heading calls it a tax free deemed return. What the struck text said is not recorded here. The tax code is not indexed on this site.
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.
“Section 250(a)(2) is amended by striking "foreign-derived intangible income" each place it appears and inserting "foreign-derived deduction eligible income".”
The section replaces foreign-derived intangible income with foreign-derived deduction eligible income in section 250(a)(1)(A) and each place it appears in section 250(a)(2) of the Internal Revenue Code of 1986. It also strikes paragraphs (1) and (2) of section 250(b), renumbers paragraphs (4) and (5) as (1) and (2) and moves them before paragraph (3), fixes a cross reference, and changes the word intangible to deduction eligible in the headings of section 250, section 172(d)(9) and the related table of sections item.
What the document actually says
“Section 250(a)(2) is amended by striking "foreign-derived intangible income" each place it appears and inserting "foreign-derived deduction eligible income".”
That sentence, in plain words
One term is taken out wherever it appears. A new term is put in its place.
What this is about
The word intangible drops out of the term. The words deduction eligible go in. Two paragraphs are struck and others renumbered.
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.
The document says “shall apply”Who acts: Secretary of the TreasuryHow: statuteSec. 70323 in the PDF
What the document says
“The amendments made by this section shall apply to taxable years beginning after December 31, 2025.”
The section applies its amendments to taxable years beginning after December 31, 2025.
What the document actually says
“The amendments made by this section shall apply to taxable years beginning after December 31, 2025.”
That sentence, in plain words
The changes start with tax years that begin after December 31, 2025.
What this is about
Earlier tax years are not touched. The old rules still hold for them. The date is fixed in the law.
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.
Each distinct thing the section does: rename the first term and carry it through the Code, repeal the deemed return provisions and renumber what is left, rename the second term and restructure the subsection around it, and fix the effective date.
The many heading, table of sections and cross reference changes that follow from the two renamings, which are carried in summaries.
The section works by amending sections 172, 250, 951A and 960 of the Internal Revenue Code of 1986, none of which is indexed here, so what the renamed provisions do cannot be checked against anything on this site.
