Permanent Extension of Look-Thru Rule for Related Controlled Foreign Corporations
Section 70351 · Sec. 70351 ·
What this chapter is about
This part takes an end date out of a rule on related foreign firms. The rule no longer runs out after 2025. The change starts with foreign firm tax years after December 31, 2025.
“Section 954(c)(6)(C) is amended by striking "and before January 1, 2026,".”
The section strikes the words and before January 1, 2026 from section 954(c)(6)(C) of the Internal Revenue Code of 1986. That provision is not indexed here, so this record states the change and stops.
What the document actually says
“Section 954(c)(6)(C) is amended by striking "and before January 1, 2026,".”
That sentence, in plain words
Words setting an end date are taken out. Those words were and before January 1, 2026.
What this is about
So the rule carries on with no end year. What the rule does 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.
The document says “shall apply”Who acts: Secretary of the TreasuryHow: statuteSec. 70351 in the PDF
What the document says
“The amendment made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025.”
The section applies its amendment to taxable years of foreign corporations beginning after December 31, 2025.
What the document actually says
“The amendment made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025.”
That sentence, in plain words
The change starts with foreign firm tax years that begin after December 31, 2025.
What this is about
Earlier tax years are not touched. The old rule still holds 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.
Both things the section does: strike the end date, and fix the effective date.
Nothing in the section is left out. It has two subsections and each is recorded.
The section works by amending section 954(c)(6)(C) of the Internal Revenue Code of 1986, which is not indexed here, so what the look-thru rule does cannot be checked against anything on this site.
