Repeal of Election for 1-Month Deferral in Determination of Taxable Year of Specified Foreign Corporations
Section 70352 · Sec. 70352 ·
What this chapter is about
This part ends a choice that let some foreign firms shift their tax year by a month. It sets when the first new tax year ends. The change starts with foreign firm tax years after November 30, 2025.
“Section 898(c) is amended by striking paragraph (2) and redesignating paragraph (3) as paragraph (2).”
The section strikes paragraph (2) of section 898(c) of the Internal Revenue Code of 1986 and renumbers paragraph (3) as paragraph (2). That provision is not indexed here, so what the struck paragraph said cannot be checked against anything on this site.
What the document actually says
“Section 898(c) is amended by striking paragraph (2) and redesignating paragraph (3) as paragraph (2).”
That sentence, in plain words
One paragraph is taken out of a tax rule. The next one is renumbered to fill the gap.
What this is about
The heading calls it a one month deferral election. What it said in full 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”Who acts: Secretary of the TreasuryHow: statuteSec. 70352 in the PDF
What the document says
“such corporation's first taxable year beginning after such date shall end at the same time as the first required year (within the meaning of section 898(c)(1) of the Internal Revenue Code of 1986) ending after such date.”
The section provides that a specified foreign corporation as of November 30, 2025 has its first taxable year beginning after that date end at the same time as the first required year ending after that date. Where the change forces a new taxable year, it is treated as initiated by the corporation and made with the Secretary's consent, and the Secretary must issue guidance for splitting foreign taxes paid or accrued in that year and the next between them.
What the document actually says
“such corporation's first taxable year beginning after such date shall end at the same time as the first required year (within the meaning of section 898(c)(1) of the Internal Revenue Code of 1986) ending after such date.”
That sentence, in plain words
The firm's first new tax year ends at a set point. That point is the first required year ending after the same date.
What this is about
A required year is fixed by the tax code. The firm counts as having asked for the change. The Secretary counts as having agreed.
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. 70352 in the PDF
What the document says
“The amendments made by this section shall apply to taxable years of specified foreign corporations beginning after November 30, 2025.”
The section applies its amendments to taxable years of specified foreign corporations beginning after November 30, 2025.
What the document actually says
“The amendments made by this section shall apply to taxable years of specified foreign corporations beginning after November 30, 2025.”
That sentence, in plain words
The changes start with tax years that begin after November 30, 2025. That covers named foreign firms.
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: strike the election, fix the effective date, and set the transition rule with the change of accounting year and the guidance on allocating foreign taxes.
The redesignation of paragraph (3) as paragraph (2), which moves existing text without changing what it requires.
The section works by amending section 898(c) of the Internal Revenue Code of 1986, which is not indexed here, so what the struck election said cannot be checked against anything on this site.
