26 U.S.C. § 898: Taxable year of certain foreign corporations

For purposes of this title, the taxable year of any specified foreign corporation shall be the required year determined under subsection (c). which is treated as a controlled foreign corporation for any purpose under subpart F of part III of this subchapter, and with respect to which the ownership requirements of paragraph (2) are met. the total voting power of all classes of stock of such corporation entitled to vote, or the total value of all classes of stock of such corporation. For purposes of subparagraph (A), the rules of subsections (a) and (b) of section 958 shall apply in determining ownership. The term “United States shareholder” has the meaning given to such term by section 951(b), except that, in the case of a foreign corporation having related person insurance income (as defined in section 953(c)(2)), the Secretary may treat any person as a United States shareholder for purposes of this section if such person is treated as a United States shareholder under section 953(c)(1). the majority U.S. shareholder year, or if there is no majority U.S. shareholder year, the taxable year prescribed under regulations. each United States shareholder described in subsection (b)(2)(A), and each United States shareholder not described in clause (i) whose stock was treated as owned under subsection (b)(2)(B) by any shareholder described in such clause. the first day of the corporation’s taxable year (determined without regard to this section), or the days during such representative period as the Secretary may prescribe. The amendments made by this section [amending this section] shall apply to taxable years of specified foreign corporations beginning after November 30, 2025 . such change shall be treated as initiated by such corporation, such change shall be treated as having been made with the consent of the Secretary, and the Secretary shall issue regulations or other guidance for allocating foreign taxes that are paid or accrued in such first taxable year and the succeeding taxable year among such taxable years in the manner the Secretary determines appropriate to carry out the purposes of this section. For purposes of this subsection, the term ‘Secretary’ means the Secretary of the Treasury or the Secretary’s delegate.” The amendments made by this section [enacting this section and amending section 563 of this title ] shall apply to taxable years of foreign corporations beginning after July 10, 1989 . such change shall be treated as initiated by the taxpayer, such change shall be treated as having been made with the consent of the Secretary of the Treasury or his delegate, and if, by reason of such change, any United States person is required to include in gross income for 1 taxable year amounts attributable to 2 taxable years of such foreign corporation, the amount which would otherwise be required to be included in gross income for such 1 taxable year by reason of the short taxable year of the foreign corporation resulting from such change shall be included in gross income ratably over the 4-taxable-year period beginning with such 1 taxable year.”