Sec. 70352. Repeal of election for 1-month deferral in determination of taxable year of specified foreign corporations
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/bill/119/hr/1/enr/section-70352A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
Section 898(c) is amended by striking paragraph
(2)and redesignating paragraph
(3)as paragraph (2). The amendments made by this section shall apply to taxable years of specified foreign corporations beginning after November 30, 2025. In the case of a corporation that is a specified foreign corporation as of November 30, 2025, 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. If any specified foreign corporation is required by the amendments made by this section to change its taxable year for its first taxable year beginning after November 30, 2025— such change shall be treated as initiated by such corporation, such change shall be treated as having been made with the consent of the Secretary, and the Secretary shall issue regulations or other guidance for allocating foreign taxes that are paid or accrued in such first taxable year and the succeeding taxable year among such taxable years in the manner the Secretary determines appropriate to carry out the purposes of this section. For purposes of this subsection, the term Secretary means the Secretary of the Treasury or the Secretary's delegate.