Sec. 70312. Modifications to determination of deemed paid credit for taxes properly attributable to tested income
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/bill/119/hr/1/eas/section-70312A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
Section 960(d)(1) is amended by striking 80 percent and inserting 90 percent . Section 78 is amended— by striking subsections (a), (b), and
(d)and inserting subsections
(a)and
(d), and by striking 80 percent and inserting 90 percent . Section 960(d) is amended by adding at the end the following new paragraph: No credit shall be allowed under section 901 for 10 percent of any foreign income taxes paid or accrued (or deemed paid under subsection (b)(1)) with respect to any amount excluded from gross income under section 959(a) by reason of an inclusion in gross income under section 951A(a). . The amendments made by subsection
(a)shall apply to taxable years beginning after December 31, 2025. The amendment made by subsection
(b)shall apply to foreign income taxes paid or accrued (or deemed paid under section 960(b)(1) of the Internal Revenue Code of 1986) with respect to any amount excluded from gross income under section 959(a) of such Code by reason of an inclusion in gross income under section 951A(a) of such Code after June 28, 2025.