Sec. 70313. Sourcing certain income from the sale of inventory produced in the United States
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Section 904(b), as amended by section 70311, is amended by adding at the end the following new paragraph: For purposes of this section, if a United States person maintains an office or other fixed place of business in a foreign country (determined under rules similar to the rules of section 864(c)(5)), the portion of income which— is from the sale or exchange outside the United States of inventory property (within the meaning of section 865(i)(1))— which is produced in the United States, which is for use outside the United States, and to which the third sentence of section 863(b) applies, and is attributable (determined under rules similar to the rules of section 864(c)(5)) to such office or other fixed place of business, shall be treated as from sources without the United States, except that the amount so treated shall not exceed 50 percent of the income from the sale or exchange of such inventory property. .
The amendment made by this section shall apply to taxable years beginning after December 31, 2025.