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139 STAT. 206 PUBLIC LAW 119–21—JULY 4, 2025 (1) IN GENERAL.—Section 250(a)(1)(A) is amended by striking ‘‘foreign-derived intangible income’’ and inserting ‘‘for- eign-derived deduction eligible income’’. (2) CONFORMING AMENDMENTS.— (A) Section 250(a)(2) is amended by striking ‘‘foreign- derived intangible income’’ each place it appears and inserting ‘‘foreign-derived deduction eligible income’’. (B) Section 250(b), as amended by subsection (a), is amended— (i) by striking paragraphs (1) and (2), (ii) by redesignating paragraphs (4) and (5) as paragraphs (1) and (2), respectively, and by moving such paragraphs before paragraph (3), (iii) in paragraph (2)(B)(ii), as so redesignated, by striking ‘‘paragraph (4)(B)’’ and inserting ‘‘paragraph (1)(B)’’, and (iv) by striking ‘‘INTANGIBLE’’ in the heading thereof and inserting ‘‘DEDUCTION ELIGIBLE’’. (C)(i) The heading for section 250 is amended by striking ‘‘INTANGIBLE’’ in the heading thereof and inserting ‘‘DEDUCTION ELIGIBLE’’. (ii) The heading for section 172(d)(9) is amended by striking ‘‘INTANGIBLE’’ and inserting ‘‘DEDUCTION ELIGIBLE’’. (iii) The item relating to section 250 in the table of sections for part VIII of subchapter B of chapter 1 is amended by striking ‘‘intangible’’ and inserting ‘‘deduction eligible’’. (c) EFFECTIVE DATE.—The amendments made by this section shall apply to taxable years beginning after December 31, 2025. PART III—BASE EROSION MINIMUM TAX SEC. 70331. EXTENSION AND MODIFICATION OF BASE EROSION MIN- IMUM TAX AMOUNT. (a) IN GENERAL.—Section 59A(b) is amended— (1) by striking ‘‘10 percent’’ in paragraph (1) and inserting ‘‘10.5 percent’’, and (2) by striking paragraph (2) and by redesignating para- graphs (3) and (4) as paragraphs (2) and (3), respectively. (b) CONFORMING AMENDMENTS.— (1) Section 59A(b)(1) is amended by striking ‘‘Except as provided in paragraphs (2) and (3)’’ and inserting ‘‘Except as provided in paragraph (2)’’. (2) Section 59A(b)(2), as redesignated by subsection (a)(2), is amended by striking ‘‘the percentage otherwise in effect under paragraphs (1)(A) and (2)(A) shall each be increased’’ and inserting ‘‘the percentages otherwise in effect under para- graph (1)(A) shall be increased’’. (3) Section 59A(e)(1)(C) is amended by striking ‘‘in the case of a taxpayer described in subsection (b)(3)(B)’’ and inserting ‘‘in the case of a taxpayer described in subsection (b)(2)(B)’’. (c) OTHER MODIFICATIONS.— (1) Section 59A(b)(2)(B)(ii), as redesignated by subsection (a)(2), is amended by striking ‘‘registered securities dealer’’ and inserting ‘‘securities dealer registered’’. 26 USC 172 note. 26 USC prec. 241.