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139 STAT. 284 PUBLIC LAW 119–21—JULY 4, 2025 (1) in the matter preceding clause (i), by striking ‘‘December 31, 2018’’ and inserting ‘‘December 31, 2025’’, and (2) in clause (ii), by striking ‘‘2017’’ and inserting ‘‘2024’’. (c) EFFECTIVE DATES.— (1) RULE MADE PERMANENT.—The amendments made by subsection (a) shall apply to taxable years beginning after December 31, 2026. (2) ADJUSTMENT OF AMOUNTS FOR CALCULATION OF EXCESS BUSINESS LOSS.—The amendments made by subsection (b) shall apply to taxable years beginning after December 31, 2025. SEC. 70602. TREATMENT OF PAYMENTS FROM PARTNERSHIPS TO PARTNERS FOR PROPERTY OR SERVICES. (a) IN GENERAL.—Section 707(a)(2) is amended by striking ‘‘Under regulations prescribed’’ and inserting ‘‘Except as provided’’. (b) EFFECTIVE DATE.—The amendment made by this section shall apply to services performed, and property transferred, after the date of the enactment of this Act. (c) RULE OF CONSTRUCTION.—Nothing in this section, or the amendments made by this section, shall be construed to create any inference with respect to the proper treatment under section 707(a) of the Internal Revenue Code of 1986 with respect to pay- ments from a partnership to a partner for services performed, or property transferred, on or before the date of the enactment of this Act. SEC. 70603. EXCESSIVE EMPLOYEE REMUNERATION FROM CON- TROLLED GROUP MEMBERS AND ALLOCATION OF DEDUCTION. (a) APPLICATION OF AGGREGATION RULES.—Section 162(m) is amended by adding at the end the following new paragraph: ‘‘(7) REMUNERATION FROM CONTROLLED GROUP MEMBERS.— ‘‘(A) IN GENERAL.—In the case of any publicly held corporation which is a member of a controlled group— ‘‘(i) paragraph (1) shall be applied by substituting ‘specified covered employee’ for ‘covered employee’, and ‘‘(ii) if any person which is a member of such controlled group (other than such publicly held corpora- tion) provides applicable employee remuneration to an individual who is a specified covered employee of such controlled group and the aggregate amount described in subparagraph (B)(ii) with respect to such specified covered employee exceeds $1,000,000— ‘‘(I) paragraph (1) shall apply to such person with respect to such remuneration, and ‘‘(II) paragraph (1) shall apply to such publicly held corporation and to each such related person by substituting ‘the allocable limitation amount’ for ‘$1,000,000’. ‘‘(B) ALLOCABLE LIMITATION AMOUNT.—For purposes of this paragraph, the term ‘allocable limitation amount’ means, with respect to any member of the controlled group referred to in subparagraph (A) with respect to any speci- fied covered employee of such controlled group, the amount which bears the same ratio to $1,000,000 as— ‘‘(i) the amount of applicable employee remunera- tion provided by such member with respect to such specified covered employee, bears to Definitions. 26 USC 707 note. 26 USC 707 note. Applicability. 26 USC 461 note.