Treatment of certain foreign entities established in connection with decentralized autonomous organizations

(a) In general Not later than12 months after the date of the enactment of this Act, the Secretary of the Treasury (or the Secretary's delegate) shall issue regulations or other guidance to clarify the appropriate tax treatment of reorganizations of applicable foreign entities (and United States persons related to such entities or involved in the governance of such entities). (b) Matters included The regulations or other guidance issued under subsection (a) shall— (1) clarify the methods by which applicable foreign entities may reorganize as domestic corporations under subchapter C of chapter 1 of the Internal Revenue Code of 1986, and (2) provide, in appropriate circumstances, temporary safe harbors to encourage applicable foreign entities organized before September 24, 2026, to complete such reorganizations promptly after the date of the enactment of this Act. (c) Applicable foreign entity For purposes of this section, the term applicable foreign entity means an entity which is established— (1) in connection with an organization commonly referred to as decentralized autonomous organizations, and (2) in a foreign country as a foundation under foreign law (or other similar structure with a purported purpose other than profit).