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139 STAT. 210 PUBLIC LAW 119–21—JULY 4, 2025 ‘‘(1) section 951(b) were applied by substituting ‘more than 50 percent’ for ‘10 percent or more’, and ‘‘(2) section 958(b) were applied without regard to para- graph (4) thereof. ‘‘(c) FOREIGN CONTROLLED FOREIGN CORPORATION.—For pur- poses of this section, the term ‘foreign controlled foreign corporation’ means a foreign corporation, other than a controlled foreign corpora- tion, which would be a controlled foreign corporation if section 957(a) were applied— ‘‘(1) by substituting ‘foreign controlled United States share- holders’ for ‘United States shareholders’, and ‘‘(2) by substituting ‘section 958(b) (other than paragraph (4) thereof)’ for ‘section 958(b)’. ‘‘(d) REGULATIONS.—The Secretary shall prescribe such regula- tions or other guidance as may be necessary or appropriate to carry out the purposes of this section, including regulations or other guidance— ‘‘(1) to treat a foreign controlled United States shareholder or a foreign controlled foreign corporation as a United States shareholder or as a controlled foreign corporation, respectively, for purposes of provisions of this title other than this subpart (including any reporting requirement), and ‘‘(2) with respect to the treatment of foreign controlled foreign corporations that are passive foreign investment compa- nies (as defined in section 1297).’’. (c) CLERICAL AMENDMENT.—The table of sections for subpart F of part III of subchapter N of chapter 1 is amended by inserting after the item relating to section 951A the following new item: ‘‘Sec. 951B. Amounts included in gross income of foreign controlled United States shareholders.’’. (d) EFFECTIVE DATE.—The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025. (e) SPECIAL RULE.— (1) IN GENERAL.—Except to the extent provided by the Secretary of the Treasury (or the Secretary’s delegate), the effective date of any amendment to the Internal Revenue Code of 1986 shall be applied by treating references to United States shareholders as including references to foreign controlled United States shareholders, and by treating references to con- trolled foreign corporations as including references to foreign controlled foreign corporations. (2) DEFINITIONS.—Any term used in paragraph (1) which is used in subpart F of part III of subchapter N of chapter 1 of the Internal Revenue Code of 1986 (as amended by this section) shall have the meaning given such term in such sub- part. (f) NO INFERENCE.—The amendments made by this section shall not be construed to create any inference with respect to the proper application of any provision of the Internal Revenue Code of 1986 with respect to taxable years beginning before the taxable years to which such amendments apply. SEC. 70354. MODIFICATIONS TO PRO RATA SHARE RULES. (a) IN GENERAL.—Subsection (a) of section 951 is amended to read as follows: ‘‘(a) AMOUNTS INCLUDED.— 26 USC 951B note. 26 USC 951B note. 26 USC 951B note. 26 USC prec. 951. Guidance.