H.R. 10431
U.S. Innovation and Global Competitiveness Act of 2026
Sponsor: Ron Estes · 0 cosponsors
Official summary
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Text of the bill
(a) In general. Section 905(c) is amended—
(1) in paragraph (1), by striking or at the end of subparagraph (B) and by inserting after subparagraph (C) the following new subparagraphs:
(D) the taxpayer makes a timely change in its choice to claim a credit or deduction for taxes paid or accrued, or
(E) there is any other change in the amount, or treatment, of taxes, which affects the taxpayer’s tax liability under this chapter,
(2) in paragraph (2)(B)(i), by inserting , except as otherwise provided by the Secretary, after shall, and
(3) in the heading, by striking accrued.
(b) Election To treat redetermined tax as paid or accrued in year of redetermination. Section 905(c) is amended by adding at the end the following new paragraph:
(6) Election to treat redetermined tax as paid or accrued in year of redetermination
(A) In general. At the irrevocable election of the taxpayer, in the case of a redetermination under paragraph (1)—
(i) accrued taxes relating to such redetermination shall be treated as accrued in the taxable year in which such redetermination occurs and shall be treated solely for the purpose of determining the amount of such increase as incurred on the date such taxes were accrued, and
(ii) the amount of any credit allowed to the taxpayer by reason of such redetermination shall be treated as allowed to such taxpayer in the taxable year in which such redetermination occurs.
(B) Regulations. The Secretary may issue such regulations to prevent abuse of this paragraph as the Secretary determines appropriate.
(c) Modification to special period of limitation. Section 6511(d)(3) is amended—
(1) in subparagraph (A)—
(A) by inserting a change in the liability for before any taxes paid or accrued,
(B) by striking actually paid and inserting paid (or deemed paid under section 960), and
(C) by inserting change in the liability for before foreign taxes in the heading thereof, and
(2) in subparagraph (B), by striking the allowance of a credit for the taxes and inserting the allowance of an additional credit by reason of the change in liability for the taxes.
(d) Effective date
(1) In general. Except as otherwise provided in this subsection, the amendments made by this section shall apply to taxes paid or accrued in taxable years beginning after December 31, 2026.
(2) Certain changes. The amendments made by paragraphs (1) and (3) of subsection (a) shall apply to changes that occur on or after the date which is 60 days after the date of the enactment of this Act.
(3) Modification to special period of limitation. The amendments made by subsection (c) shall apply to taxes paid, accrued, or deemed paid in taxable years beginning after December 31, 2026.