Sec. 70323. Rules related to deemed intangible income
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Section 951A(a) is amended by striking global intangible low-taxed income and inserting net CFC tested income . 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. Section 250 is amended by striking global intangible low-taxed income each place it appears in subsections (a)(1)(B)(i), (a)(2), and (b)(3)(A)(i)(II) and inserting net CFC tested income . The heading for section 250 of such Code is amended by striking and inserting Global Intangible Low-Taxed Income . Net CFC Tested Income The item relating to section 250 in the table of sections for part VII of subchapter B of chapter 1 of such Code is amended by striking global intangible low-taxed income and inserting net CFC tested income . Section 951A(c)(1), as redesignated by paragraph (2), is amended by striking subsections (b), (c)(1)(A), and (c)(1)(B) and inserting subsections (b)(1)(A) and (b)(1)(B) . Section 951A(d), as redesignated by paragraph (2), is amended— by striking global intangible low-taxed income each place it appears and inserting net CFC tested income , and by striking subsection (c)(1)(A) in paragraph (2)(B)(ii) and inserting subsection (b)(1)(A) . Section 960(d)(2) is amended— by striking global intangible low-taxed income in subparagraph
(A)and inserting net CFC tested income , and by striking section 951A(c)(1)(A) in subparagraph
(B)and inserting section 951A(b)(1)(A) . The heading for section 951A is amended by striking and inserting Global Intangible Low-Taxed Income . Net CFC Tested Income The item relating to section 951A in the table of sections for subpart F of part III of subchapter N of chapter 1 is amended by striking Global intangible low-taxed income and inserting Net CFC tested income . Section 250(a)(1)(A) is amended by striking foreign-derived intangible income and inserting foreign-derived deduction eligible income . Section 250(a)(2) is amended by striking foreign-derived intangible income each place it appears and inserting foreign-derived deduction eligible income . Section 250(b), as amended by subsection (a), is amended— by striking paragraphs
(1)and (2), by redesignating paragraphs
(4)and
(5)as paragraphs
(1)and (2), respectively, and by moving such paragraphs before paragraph (3), in paragraph (2)(B)(ii), as so redesignated, by striking paragraph (4)(B) and inserting paragraph (1)(B) , and by striking in the heading thereof and inserting intangible . deduction eligible The heading for section 250 is amended by striking in the heading thereof and inserting intangible . deduction eligible The heading for section 172(d)(9) is amended by striking and inserting intangible . deduction eligible The item relating to section 250 in the table of sections for part VIII of subchapter B of chapter 1 is amended by striking intangible and inserting deduction eligible . The amendments made by this section shall apply to taxable years beginning after December 31, 2025.