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 78 (and the portion of the deductions allowed under sections 245A(a) (by reason of section 964(e)(4)) and 250(a)(1)(B) by reason of such inclusions), and. (b) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2025.