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139 STAT. 202 PUBLIC LAW 119–21—JULY 4, 2025 ‘payload’, ‘reentry services’, ‘reentry site’, a ‘reentry vehicle’ shall have the respective meanings given to such terms by section 50902 of title 51, United States Code (as in effect on the date of enactment of this subsection). ‘‘(3) PUBLIC USE REQUIREMENT.—A facility shall not be required to be available for use by the general public to be treated as a spaceport for purposes of this section. ‘‘(4) MANUFACTURING FACILITIES AND INDUSTRIAL PARKS ALLOWED.—With respect to spaceports, subsection (c)(2)(E) shall not apply to spaceport property described in paragraph (1)(A).’’. (d) EXCEPTION FROM FEDERALLY GUARANTEED BOND PROHIBI- TION.—Section 149(b)(3) is amended by adding at the end the fol- lowing new subparagraph: ‘‘(F) EXCEPTION FOR SPACEPORTS.—A bond shall not be treated as federally guaranteed merely because of the payment of rent, user fees, or other charges by the United States (or any agency or instrumentality thereof) in exchange for the use of the spaceport by the United States (or any agency or instrumentality thereof).’’. (e) CONFORMING AMENDMENT.—The heading for section 142(c) is amended by inserting ‘‘SPACEPORTS,’’ after ‘‘AIRPORTS,’’. (f) EFFECTIVE DATE.—The amendments made by this section shall apply to obligations issued after the date of the enactment of this Act. Subchapter B—Permanent America-first International Tax Reforms PART I—FOREIGN TAX CREDIT SEC. 70311. MODIFICATIONS RELATED TO FOREIGN TAX CREDIT LIMITATION. (a) RULES FOR ALLOCATION OF CERTAIN DEDUCTIONS TO FOR- EIGN 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) DEDUCTIONS TREATED AS ALLOCABLE TO FOREIGN SOURCE NET CFC TESTED INCOME.—Solely for purposes of the application of subsection (a) with respect to amounts described in subsection (d)(1)(A), the taxpayer’s taxable income from sources without the United States shall be determined by allo- cating and apportioning— ‘‘(A) any deduction allowed under section 250(a)(1)(B) (and any deduction allowed under section 164(a)(3) for taxes imposed on amounts described in section 250(a)(1)(B)) to such income, ‘‘(B) no amount of interest expense or research and experimental expenditures to such income, and ‘‘(C) any other deduction to such income only if such deduction is directly allocable to such income. Any amount or deduction which would (but for subparagraphs (B) and (C)) have been allocated or apportioned to such income shall only be allocated or apportioned to income which is from sources within the United States.’’. (b) OTHER MODIFICATIONS.— (1) Section 904(d)(2)(H)(i) is amended by striking ‘‘para- graph (1)(B)’’ and inserting ‘‘paragraph (1)(D)’’. 26 USC 142 note.