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  • Sec. 70353. Restoration of limitation on downward attribution of stock ownership in applying constructive ownership rules

    Home/All Topics/OBBBA Text(a) In general.—Section 958(b) is amended— (1) by inserting after paragraph (3) the following: “(4) Subparagraphs (A), (B), and (C) of section 318(a)(3) shall not be applied so as to consider a United States person as owning stock which is owned by a person who is not a United States person.”, and (2)…

  • Sec. 70352. Repeal of election for 1-month deferral in determination of taxable year of specified foreign corporations

    Home/All Topics/OBBBA Text(a) In general.—Section 898(c) is amended by striking paragraph (2) and redesignating paragraph (3) as paragraph (2). (b) Effective date.—The amendments made by this section shall apply to taxable years of specified foreign corporations beginning after November 30, 2025. (c) Transition rule.— (1) IN GENERAL.—In the case of a corporation that is a…

  • Sec. 70351. Permanent extension of look-thru rule for related controlled foreign corporations

    Home/All Topics/OBBBA Text(a) In general.—Section 954(c)(6)(C) is amended by striking “and before January 1, 2026,”. (b) Effective date.—The amendment made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025. ← PART IV—BUSINESS INTEREST LIMITATIONOBBBA TextAll TopicsBack to top ↑Sec. 70352. Repeal of election for 1-month deferral in determination…

  • PART IV—BUSINESS INTEREST LIMITATION

    Home/All Topics/OBBBA TextSEC. 70341. Coordination of business interest limitation with interest capitalization provisions. (a) In general.—Section 163(j) is amended by redesignating paragraphs (10) and (11) as paragraphs (11) and (12) and by inserting after paragraph (9) the following: “(10) COORDINATION WITH INTEREST CAPITALIZATION PROVISIONS.— “(A) IN GENERAL.—In applying this subsection— “(i) the limitation under paragraph…

  • Sec. 70342. Definition of adjusted taxable income for business interest limitation

    Home/All Topics/OBBBA TextSEC. 70342. Definition of adjusted taxable income for business interest limitation. (a) In general.—Subparagraph (A) of section 163(j)(8) is amended— (1) by striking “and” at the end of clause (iv), and (2) by adding at the end the following new clause: “(vi) the amounts included in gross income under sections 951(a), 951A(a), and…

  • Sec. 70341. Coordination of business interest limitation with interest capitalization provisions

    Home/All Topics/OBBBA Text(a) In general.—Section 163(j) is amended by redesignating paragraphs (10) and (11) as paragraphs (11) and (12) and by inserting after paragraph (9) the following: “(10) COORDINATION WITH INTEREST CAPITALIZATION PROVISIONS.— “(A) IN GENERAL.—In applying this subsection— “(i) the limitation under paragraph (1) shall apply to business interest without regard to whether the…

  • PART III—BASE EROSION MINIMUM TAX

    Home/All Topics/OBBBA TextSEC. 70331. Extension and modification of base erosion minimum tax amount. (a) In general.—Section 59A(b) is amended— (1) by striking “10 percent” in paragraph (1) and inserting “10.5 percent”, and (2) by striking paragraph (2) and by redesignating paragraphs (3) and (4) as paragraphs (2) and (3), respectively. (b) Conforming amendments.— (1) Section…

  • Sec. 70331. Extension and modification of base erosion minimum tax amount

    Home/All Topics/OBBBA Text(a) In general.—Section 59A(b) is amended— (1) by striking “10 percent” in paragraph (1) and inserting “10.5 percent”, and (2) by striking paragraph (2) and by redesignating paragraphs (3) and (4) as paragraphs (2) and (3), respectively. (b) Conforming amendments.— (1) Section 59A(b)(1) is amended by striking “Except as provided in paragraphs (2)…

  • PART II—FOREIGN-DERIVED DEDUCTION ELIGIBLE INCOME AND NET CFC TESTED INCOME

    Home/All Topics/OBBBA TextSEC. 70321. Modification of deduction for foreign-derived deduction eligible income and net CFC tested income. (a) In general.—Section 250(a) is amended— (1) by striking “37.5 percent” in paragraph (1)(A) and inserting “33.34 percent”, (2) by striking “50 percent” in paragraph (1)(B) and inserting “40 percent”, and (3) by striking paragraph (3). (b) Effective…

  • Sec. 70323. Rules related to deemed intangible income

    Home/All Topics/OBBBA Text(a) Taxation of net CFC tested income.— (1) IN GENERAL.—Section 951A(a) is amended by striking “global intangible low-taxed income” and inserting “net CFC tested income”. (2) REPEAL OF TAX-FREE DEEMED RETURN ON FOREIGN INVESTMENTS.—Section 951A, as amended by the preceding provisions of this Act, is amended by striking subsections (b) and (d) and…

  • Sec. 70322. Determination of deduction eligible income

    Home/All Topics/OBBBA Text(a) Sales or other dispositions of certain property.— (1) IN GENERAL.—Section 250(b)(3)(A)(i) is amended— (A) by striking “and” at the end of subclause (V), (B) by striking “over” at the end of subclause (VI) and inserting “and”, and (C) by adding at the end the following new subclause: “(VII) except as otherwise provided…

  • Sec. 70321. Modification of deduction for foreign-derived deduction eligible income and net CFC tested income

    Home/All Topics/OBBBA Text(a) In general.—Section 250(a) is amended— (1) by striking “37.5 percent” in paragraph (1)(A) and inserting “33.34 percent”, (2) by striking “50 percent” in paragraph (1)(B) and inserting “40 percent”, and (3) by striking paragraph (3). (b) Effective date.—The amendments made by this section shall apply to taxable years beginning after December 31,…