Redetermination of foreign taxes and related claims

(a) In general Section 905(c) is amended— (1) in paragraph (1), by striking or at the end of subparagraph (B) and by inserting after subparagraph (C) the following new subparagraphs: (D) the taxpayer makes a timely change in its choice to claim a credit or deduction for taxes paid or accrued, or (E) there is any other change in the amount, or treatment, of taxes, which affects the taxpayer’s tax liability under this chapter,, (2) in paragraph (2)(B)(i), by inserting, except as otherwise provided by the Secretary, after shall, and (3) by striking accrued in the heading thereof. (b) Modification to time for claiming credit or deduction Section 901(a) is amended by striking the second sentence and inserting the following: Such choice for any taxable year may be made or changed at any time before the expiration of the applicable period prescribed by section 6511 for making a claim for credit or refund of an overpayment of the tax imposed by this chapter for such taxable year that is attributable to such amounts.. (c) Modification to special period of limitation Section 6511(d)(3) is amended— (1) in subparagraph (A)— (A) by inserting a change in the liability for before any taxes paid or accrued, (B) by striking actually paid and inserting paid (or deemed paid under section 960), and (C) by inserting change in the liability for before foreign taxes in the heading thereof, and (2) in subparagraph (B), by striking the allowance of a credit for the taxes and inserting the allowance of an additional credit by reason of the change in liability for the taxes. (d) Effective date (1) In general Except as otherwise provided in this subsection, the amendments made by this section shall apply to taxes paid or accrued in taxable years beginning after December 31, 2025. (2) Certain changes The amendments made by paragraphs (1) and (3) of subsection (a) shall apply to changes that occur on or after the date which is 60 days after the date of the enactment of this Act. (3) Modification to special period of limitation The amendments made by subsection (c) shall apply to taxes paid, accrued, or deemed paid in taxable years beginning after December 31, 2025.