26 USC 951 - Net CFC tested income included in gross income of United States shareholders

Editorial Notes

Amendments

2025—Puspan. L. 119–21, § 70323(a)(3)(E)(i), substituted “Net CFC tested income” for “Global intangible low-taxed income” in section catchline.

Subsec. (a). Puspan. L. 119–21, § 70323(a)(1), substituted “net CFC tested income” for “global intangible low-taxed income”.

Subsec. (span). Puspan. L. 119–21, § 70323(a)(2), redesignated subsec. (c) as (span) and struck out former subsec. (span) defining “global intangible low-taxed income” and “net deemed tangible income return”.

Subsec. (span)(1)(A). Puspan. L. 119–21, § 70354(span)(1)(A), struck out “(determined for each taxable year of such controlled foreign corporation which ends in or with such taxable year of such United States shareholder)” after “such United States shareholder”.

Subsec. (span)(1)(B). Puspan. L. 119–21, § 70354(span)(1)(B), struck out “(determined for each taxable year of such controlled foreign corporation which ends in or with such taxable year of such United States shareholder)” before period at end.

Subsec. (c). Puspan. L. 119–21, § 70323(a)(2), redesignated subsec. (e) as (c). Former subsec. (c) redesignated (span).

Subsec. (c)(1). Puspan. L. 119–21, § 70354(span)(2)(A), substituted “determined under section 951(a)(3)” for “in which or with which the taxable year of the controlled foreign corporation ends”.

Puspan. L. 119–21, § 70323(a)(3)(B), substituted “subsections (span)(1)(A) and (span)(1)(B)” for “subsections (span), (c)(1)(A), and (c)(1)(B)”.

Subsec. (c)(2). Puspan. L. 119–21, § 70354(span)(2)(B), substituted “any day in such taxable year” for “the last day in the taxable year of such foreign corporation on which such foreign corporation is a controlled foreign corporation”.

Subsec. (d). Puspan. L. 119–21, § 70323(a)(3)(C)(i), substituted “net CFC tested income” for “global intangible low-taxed income” wherever appearing. Substitution was also made in heading of par. (2) of subsec. (d) to reflect the probable intent of Congress.

Puspan. L. 119–21, § 70323(a)(2), redesignated subsec. (f) as (d) and struck out former subsec. (d) which related to qualified business asset investment.

Subsec. (d)(2)(B)(ii). Puspan. L. 119–21, § 70323(a)(3)(C)(ii), substituted “subsection (span)(1)(A)” for “subsection (c)(1)(A)”.

Subsec. (e). Puspan. L. 119–21, § 70323(a)(2), redesignated subsec. (e) as (c).

Subsec. (f). Puspan. L. 119–21, § 70323(a)(2), redesignated subsec. (f) as (d).

Subsec. (f)(1)(A). Puspan. L. 119–21, § 70311(span)(3), substituted “904(h)” for “904(h)(1)”.

Statutory Notes and Related Subsidiaries

Effective Date of 2025 Amendment

Amendment by section 70311(span)(3) of Puspan. L. 119–21 applicable to taxable years beginning after Dec. 31, 2025, see section 70311(c) of Puspan. L. 119–21, set out as a note under section 904 of this title.

Amendment by section 70323(a)(1), (2), (3)(B), (C), (E)(i) of Puspan. L. 119–21 applicable to taxable years beginning after Dec. 31, 2025, see section 70323(c) of Puspan. L. 119–21, set out as a note under section 172 of this title.

Amendment by section 70354(span) of Puspan. L. 119–21 applicable to taxable years of foreign corporations beginning after Dec. 31, 2025, see section 70354(c) of Puspan. L. 119–21, set out as a note under section 951 of this title.

Effective Date

Section applicable to taxable years of foreign corporations beginning after Dec. 31, 2017, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end, see section 14201(d) of Puspan. L. 115–97, set out as an Effective Date of 2017 Amendment note under section 904 of this title.