Corporations exempt from subpart F inclusion for investment in United States property

(a) In general Section 956(a) is amended by inserting (other than a corporation) after United States shareholder in the matter preceding paragraph (1). (b) Effective date The amendment made by this section shall apply to taxable years of controlled foreign corporations ending after December 31, 2025, and to taxable years of United States shareholders with or within which such taxable years of controlled foreign corporations end.