Carryover of net CFC tested loss

(a) In general Section 951A(c) is amended by adding at the end the following new paragraph: (3) Carryover of net CFC tested loss (A) In general If the amount described in paragraph (1)(B) with respect to any United States shareholder for any taxable year of such United States shareholder (determined after the application of this paragraph with respect to amounts arising in preceding taxable years) exceeds the amount described in paragraph (1)(A) with respect to such shareholder of such taxable year, the amount otherwise described in paragraph (1)(B) with respect to such shareholder for the succeeding taxable year shall be increased by the amount of such excess. (B) Proper adjustment in allocations of global intangible low-taxed income to controlled foreign corporations Proper adjustments shall be made in the application of subsection (f)(2)(B) to take into account any decrease in global intangible low-taxed income by reason of the application of subparagraph (A).. (b) Application of rules with respect to ownership changes Section 382(d) is amended by adding at the end the following new paragraph: (4) Application to carryover of net CFC tested loss The term pre-change loss shall include any excess carried over under section 951A(c)(3) under rules similar to the rules of paragraph (1).. (c) Effective date The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end.