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 59A(b)(1) is amended by striking Except as provided in paragraphs (2) and (3) and inserting Except as provided in paragraph (2). (2) Section 59A(b)(2), as redesignated by subsection (a)(2), is amended by striking the percentage otherwise in effect under paragraphs (1)(A) and (2)(A) shall each be increased and inserting the percentages otherwise in effect under paragraph (1)(A) shall be increased. (3) Section 59A(e)(1)(C) is amended by striking in the case of a taxpayer described in subsection (b)(3)(B) and inserting in the case of a taxpayer described in subsection (b)(2)(B). (c) Other modifications (1) Section 59A(b)(2)(B)(ii), as redesignated by subsection (a)(2), is amended by striking registered securities dealer and inserting securities dealer registered. (2) Section 59A(h)(2)(B) is amended by striking section 6038B(b)(2) and inserting section 6038A(b)(2). (3) Section 59A(i)(2) is amended— (A) by striking subsection (g) and inserting subsection (h), and (B) by striking subsection (g)(3) and inserting subsection (h)(3). (d) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2025.

(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) and (3) and inserting Except as provided in paragraph (2). (2) Section 59A(b)(2), as redesignated by subsection (a)(2), is amended by striking the percentage otherwise in effect under paragraphs (1)(A) and (2)(A) shall each be increased and inserting the percentages otherwise in effect under paragraph (1)(A) shall be increased. (3) Section 59A(e)(1)(C) is amended by striking in the case of a taxpayer described in subsection (b)(3)(B) and inserting in the case of a taxpayer described in subsection (b)(2)(B). (c) Other modifications (1) Section 59A(b)(2)(B)(ii), as redesignated by subsection (a)(2), is amended by striking registered securities dealer and inserting securities dealer registered. (2) Section 59A(h)(2)(B) is amended by striking section 6038B(b)(2) and inserting section 6038A(b)(2). (3) Section 59A(i)(2) is amended— (A) by striking subsection (g) and inserting subsection (h), and (B) by striking subsection (g)(3) and inserting subsection (h)(3). (d) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2025.