Par. 7. Section 1.951A-7 is amended by: 1. Revising paragraph (a); and 2. Adding paragraph (c). The revision and addition read as follows:
(a) In general. Except as otherwise provided in this section, § 1.951A-1 applies to taxable years of foreign corporations beginning after December 31, 2025, and to taxable years of United States shareholders for which such taxable years of those foreign corporations are relevant. For rules applicable to taxable years of foreign corporations beginning on or before such date, and to taxable years of United States shareholders in which or with which such taxable years end, see 26 CFR 1.951A-1 as contained in 26 CFR part 1 edition revised as of April 1, 2026. Except as otherwise provided in this section, §§ 1.951A-2 through 1.951A-6 apply to taxable years of foreign corporations beginning after December 31, 2017, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end.
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(c) Transition rule for global intangible low-taxed income. In the case of a taxable year of a foreign corporation beginning after December 31, 2025, that ends with or within a taxable year of a United States shareholder beginning on or before December 31, 2025, 26 CFR 1.951A-1 as contained in 26 CFR part 1 edition revised as of April 1, 2026 applies with respect to such United States shareholder, taking into account the amendments to section 951(a)(2) made by section 70354(a) of Public Law 119-21, 139 Stat. 72 (July 4, 2025) when determining the United States shareholder's pro rata share of any tested item.