Repeal of election for 1-month deferral in determination of taxable year of specified foreign corporations

(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 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— (A) such change shall be treated as initiated by such corporation, (B) such change shall be treated as having been made with the consent of the Secretary, and (C) 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. (2) Secretary For purposes of this subsection, the term Secretary means the Secretary of the Treasury or the Secretary's delegate.

(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 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— (A) such change shall be treated as initiated by such corporation, (B) such change shall be treated as having been made with the consent of the Secretary, and (C) 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. (2) Secretary For purposes of this subsection, the term Secretary means the Secretary of the Treasury or the Secretary's delegate.