Par. 8. Section 1.960-7 is amended by: 1. In paragraph (a), removing the language “paragraph (b)” and adding “paragraphs (b) and (c)” in its place; and 2. Adding paragraph (c). The addition reads as follows:
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(c) Section 1.960-3(b)(6) applies to foreign income taxes paid or accrued (or deemed paid under section 960(b)(1)) with respect to an amount excluded from gross income under section 959(a) by reason of an inclusion in gross income under section 951A(a), to the extent the inclusion occurs in a taxable year of a United States shareholder ending after June 28, 2025. Section 1.960-3(c)(2) applies to taxable years of foreign corporations ending with or within taxable years of United States shareholders ending after June 28, 2025. For taxable years of foreign corporations ending on or after December 4, 2018, and beginning before the taxable year described in the preceding sentence, see § 1.960-3(c)(2) as contained in 26 CFR part 1 revised as of April 1, 2026.