1、 This report reflects the legislation signed into law by the president on July 4,2025(Pub.L.No.119-21)and was last updated with new observations on July 28,2025._ International tax provisions in“One Big Beautiful Bill Act”KPMG analysis and observations 2025 KPMG LLP,a Delaware limited liability part

2、nership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited,a private English company limited by guarantee.All rights reserved.The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG glo

3、bal organization.2 Contents Introduction.3 Changes to the subpart F rules.4 Permanent extension of look-thru rule for controlled foreign corporations.4 Repeal of election for one-month deferral in determination of tax year of specified foreign corporations.4 Restoration of limitation on downward att

4、ribution of stock ownership in applying constructive ownership rules.6 Modifications to the pro rata share rules.8 GILTI changes.10 Other GILTI modifications.11 Rules for allocation of certain deductions for purposes of FTC limitation and changes to certain cross-references.12 Modifications to deter

5、mination of deemed paid credit for taxes properly attributable to tested income.14 Modifications to FDII.15 Modifications to BEAT.17 Sourcing certain income from the sale of inventory produced in the United States.18 Other relevant changes.19 Section 174.19 Section 163(j).20 Enforcement of remedies

6、against unfair foreign taxes.21 Contact us.23 2025 KPMG LLP,a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited,a private English company limited by guarantee.All rights reserved.The KPMG na