Highlights: U.S. International Tax – Section 898(c)(2) Repeal – Impact to CFC Tax Years

The repeal of Section 898(c)(2) in the One Big Beautiful Bill Act (OBBBA) marks a significant shift in U.S. international tax law, eliminating the one-month tax year deferral for Controlled Foreign Corporations (CFCs). This change introduces complex challenges for income timing, foreign tax credit allocation, and overall compliance.

To help you navigate this new landscape, Bloomberg Tax developed Highlights: U.S. International Tax – Section 898(c)(2) Repeal – Impact to CFC Tax Years, a comprehensive report to help you understand the repeal and stay compliant.

Key topics include:

Planning for short taxable years
Guidance on foreign tax allocation
Foreign currency adjustments through updates to §987 regulations
IRS guidance (Notice 2025-72)

Download your complimentary copy today for in-depth analysis of key repeal impacts and strategic guidance.

First Name

Last Name

Email Address

Job Title

Company

Organization Type

Business Phone

Country

Headquarter States/Territory

Headquarter Zip/Postal Code

By submitting this information, I agree to the privacy policy and to be contacted about Bloomberg Industry Group products and services.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.