Repeal of foreign tax credit haircut for global intangible low-taxed income

(a) In general Section 960(d)(1) is amended by striking 80 percent of. (b) Conforming amendment Section 78 is amended by striking (determined without regard to the phrase 80 percent of in subsection (d)(1) thereof). (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.