(a) In general.—Paragraph (2) of section 21(a) is amended to read as follows: “(2) APPLICABLE PERCENTAGE DEFINED.—For purposes of paragraph (1), the term ‘applicable percentage’ means 50 percent— “(A) reduced (but not below 35 percent) by 1 percentage point for each $2,000 or fraction thereof by
(a) In general.—Section 129(a)(2)(A) is amended by striking “$5,000 ($2,500” and inserting “$7,500 ($3,750”. (b) Effective date.—The amendment made by this section shall apply to taxable years beginning after December 31, 2025. Published with DiscussionBridge from the Repeal OBBBA Forum Source
(a) In general.—Section 23(d)(3) is amended— (1) in subparagraph (A), by inserting “or Indian tribal government” after “a State”, and (2) in subparagraph (B), by inserting “or Indian tribal government” after “such State”. (b) Effective date.—The amendments made by this section shall apply to taxable years
(a) In general.—Section 23(a) is amended by adding at the end the following new paragraph: “(4) PORTION OF CREDIT REFUNDABLE.—So much of the credit allowed under paragraph (1) as does not exceed $5,000 shall be treated as a credit allowed under subpart C and not as
(a) Increase of amount of qualified child care expenditures taken into account.—Section 45F(a)(1) is amended by striking “25 percent” and inserting “40 percent (50 percent in the case of an eligible small business)”. (b) Increase of maximum credit amount.—Subsection (b) of section 45F is amended to
PART I—Foreign tax credit SEC. 70311. Modifications related to foreign tax credit limitation. (a) Rules for allocation of certain deductions to foreign source net CFC tested income for purposes of foreign tax credit limitation.—Section 904(b) is amended by adding at the end the following new paragraph: “(5)
SUBCHAPTER A—PERMANENT U.S. BUSINESS TAX REFORM AND BOOSTING DOMESTIC INVESTMENT SEC. 70301. Full expensing for certain business property. (a) Made permanent.— (1) IN GENERAL.—Section 168(k)(2)(A) is amended by adding “and” at the end of clause (i), by striking “, and” at the end of clause
SEC. 70351. Permanent extension of look-thru rule for related controlled foreign corporations. (a) In general.—Section 954(c)(6)(C) is amended by striking “and before January 1, 2026,”. (b) Effective date.—The amendment made by this section shall apply to taxable years of foreign corporations beginning after December
(a) In general.—Subsection (a) of section 951 is amended to read as follows: “(a) Amounts included.— “(1) IN GENERAL.—If a foreign corporation is a controlled foreign corporation at any time during a taxable year of the foreign corporation (in this subsection referred to as the ‘CFC year’)— “(A)
(a) In general.—Section 958(b) is amended— (1) by inserting after paragraph (3) the following: “(4) Subparagraphs (A), (B), and (C) of section 318(a)(3) shall not be applied so as to consider a United States person as owning stock which is owned by a person who is
(a) In general.—Section 898(c) is amended by striking paragraph (2) and redesignating paragraph (3) as paragraph (2). (b) Effective date.—The amendments made by this section shall apply to taxable years of specified foreign corporations beginning after November 30, 2025. (c) Transition rule.— (1) IN GENERAL.—In the
(a) In general.—Section 954(c)(6)(C) is amended by striking “and before January 1, 2026,”. (b) Effective date.—The amendment made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025. Published with DiscussionBridge from the Repeal OBBBA Forum Source author: Editor