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139 STAT. 208 PUBLIC LAW 119–21—JULY 4, 2025 (c) REGULATORY AUTHORITY.—Section 163(j), as amended by subsection (a), is amended by redesignating paragraphs (11) and (12) as paragraphs (12) and (13) and by inserting after paragraph (10) the following: ‘‘(11) REGULATORY AUTHORITY.—The Secretary shall issue such regulations or guidance as may be necessary or appro- priate to carry out the purposes of this subsection, including regulations or guidance to determine which business interest is taken into account under this subsection and section 59A(c)(3).’’. (d) EFFECTIVE DATE.—The amendments made by this section shall apply to taxable years beginning after December 31, 2025. SEC. 70342. DEFINITION OF ADJUSTED TAXABLE INCOME FOR BUSI- NESS INTEREST LIMITATION. (a) IN GENERAL.—Subparagraph (A) of section 163(j)(8) is amended— (1) by striking ‘‘and’’ at the end of clause (iv), and (2) by adding at the end the following new clause: ‘‘(vi) the amounts included in gross income under sections 951(a), 951A(a), and 78 (and the portion of the deductions allowed under sections 245A(a) (by rea- son of section 964(e)(4)) and 250(a)(1)(B) by reason of such inclusions), and’’. (b) EFFECTIVE DATE.—The amendments made by this section shall apply to taxable years beginning after December 31, 2025. PART V—OTHER INTERNATIONAL TAX REFORMS 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 31, 2025. SEC. 70352. REPEAL OF ELECTION FOR 1-MONTH DEFERRAL IN DETER- MINATION OF TAXABLE YEAR OF SPECIFIED FOREIGN CORPORATIONS. (a) IN GENERAL.—Section 898(c) is amended by striking para- graph (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 begin- ning after November 30, 2025. (c) TRANSITION RULE.— (1) IN GENERAL.—In the case of a corporation that is a specified foreign corporation as of November 30, 2025, such corporation’s first taxable year beginning after such date shall end at the same time as the first required year (within the meaning of section 898(c)(1) of the Internal Revenue Code of 1986) ending after such date. If any specified foreign corporation is required by the amendments made by this section to change its taxable year for its first taxable year beginning after November 30, 2025— Effective date. 26 USC 898 note. 26 USC 954 note. 26 USC 163 note. 26 USC 163 note. Guidance. Determination.