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139 STAT. 211 PUBLIC LAW 119–21—JULY 4, 2025 ‘‘(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) each United States shareholder which owns (within the meaning of section 958(a)) stock in such cor- poration on any day during the CFC year shall include in gross income such shareholder’s pro rata share (deter- mined under paragraph (2)) of the corporation’s subpart F income for the CFC year, and ‘‘(B) each United States shareholder which owns (within the meaning of section 958(a)) stock in such cor- poration on the last day, in the CFC year, on which such corporation is a controlled foreign corporation shall include in gross income the amount determined under section 956 with respect to such shareholder for the CFC year (but only to the extent not excluded from gross income under section 959(a)(2)). ‘‘(2) PRO RATA SHARE OF SUBPART F INCOME.—A United States shareholder’s pro rata share of a controlled foreign cor- poration’s subpart F income for a CFC year shall be the portion of such income which is attributable to— ‘‘(A) the stock of such corporation owned (within the meaning of section 958(a)) by such shareholder, and ‘‘(B) any period of the CFC year during which— ‘‘(i) such shareholder owned (within the meaning of section 958(a)) such stock, ‘‘(ii) such shareholder was a United States share- holder of such corporation, and ‘‘(iii) such corporation was a controlled foreign cor- poration. ‘‘(3) TAXABLE YEAR OF INCLUSION.—Any amount required to be included in gross income by a United States shareholder under paragraph (1) with respect to a CFC year shall be included in gross income for the shareholder’s taxable year which includes the last day on which the shareholder owns (within the meaning of section 958(a)) stock in the controlled foreign corporation during such CFC year. ‘‘(4) REGULATORY AUTHORITY.—The Secretary shall pre- scribe such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this subsection, including regulations or other guidance allowing taxpayers to elect, or requiring taxpayers, to close the taxable year of a controlled foreign corporation upon a direct or indirect disposi- tion of stock of such corporation.’’. (b) COORDINATION WITH SECTION 951A.— (1) TESTED INCOME.—Section 951A(b), as redesignated by section 70323(a)(2), is amended— (A) in paragraph (1)(A), by striking ‘‘(determined for each taxable year of such controlled foreign corporation which ends in or with such taxable year of such United States shareholder)’’, and (B) in paragraph (1)(B), by striking ‘‘(determined for each taxable year of such controlled foreign corporation which ends in or with such taxable year of such United States shareholder)’’. Guidance.