This Act may be cited as the Territorial Tax Parity Act of 2025.

(a) In general Section 937(b)(2) of the Internal Revenue Code of 1986 is amended by inserting, but only to the extent such income is attributable to an office or fixed place of business within the United States (determined under the rules of section 864(c)(5)) before the period at the end. (b) Source rules for personal property sales Section 865(j)(3) of such Code is amended by inserting, 932, after 931. (c) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2024.