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139 STAT. 212 PUBLIC LAW 119–21—JULY 4, 2025 (2) PRO RATA SHARE.—Section 951A(c), as redesignated by section 70323(a)(2), is amended— (A) in paragraph (1), by striking ‘‘in which or with which the taxable year of the controlled foreign corporation ends’’ and inserting ‘‘determined under section 951(a)(3)’’, and (B) in paragraph (2), by striking ‘‘the last day in the taxable year of such foreign corporation on which such foreign corporation is a controlled foreign corporation’’ and inserting ‘‘any day in such taxable year’’. (c) EFFECTIVE DATES.— (1) IN GENERAL.—The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025. (2) TRANSITION RULE FOR DIVIDENDS.—Except to the extent provided by the Secretary of the Treasury (or the Secretary’s delegate), a dividend paid (or deemed paid) by a controlled foreign corporation shall not be treated as a dividend for pur- poses of applying section 951(a)(2)(B) of the Internal Revenue Code of 1986 (as in effect before the amendments made by this section) if— (A) such dividend— (i) was paid (or deemed paid) on or before June 28, 2025, during the taxable year of such controlled foreign corporation which includes such date and the United States shareholder described in section 951(a)(1) of such Code (as so in effect) did not own (within the meaning of section 958(a) of such Code) the stock of such controlled foreign corporation during the portion of such taxable year on or before June 28, 2025, or (ii) was paid (or deemed paid) after June 28, 2025, and before such controlled foreign corporation’s first taxable year beginning after December 31, 2025, and (B) such dividend does not increase the taxable income of a United States person that is subject to Federal income tax for the taxable year (including by reason of a dividends received deduction, an exclusion from gross income, or an exclusion from subpart F income). CHAPTER 4—INVESTING IN AMERICAN FAMILIES, COMMUNITIES, AND SMALL BUSINESSES Subchapter A—Permanent Investments in Families and Children SEC. 70401. ENHANCEMENT OF EMPLOYER-PROVIDED CHILD CARE CREDIT. (a) INCREASE OF AMOUNT OF QUALIFIED CHILD CARE EXPENDI- TURES TAKEN INTO ACCOUNT.—Section 45F(a)(1) is amended by striking ‘‘25 percent’’ and inserting ‘‘40 percent (50 percent in the case of an eligible small business)’’. (b) INCREASE OF MAXIMUM CREDIT AMOUNT.—Subsection (b) of section 45F is amended to read as follows: ‘‘(b) DOLLAR LIMITATION.— 26 USC 951 note.