‘‘the greater of undistributed specified net income or 
undistributed net investment income’’. 
(c) CLARIFICATIONS WITH RESPECT
TO DETER-
MINATION OF NET INVESTMENT INCOME.— 
(1) CERTAIN EXCEPTIONS.—Section 1411(c)(6) 
of the Internal Revenue Code of 1986 is amended to 
read as follows: 
‘‘(6) SPECIAL RULES.—Net investment income 
shall not include— 
‘‘(A) any item taken into account in deter-
mining self-employment income for such taxable 
year on which a tax is imposed by section 
1401(b), 
‘‘(B) wages received with respect to em-
ployment on which a tax is imposed under sec-
tion 3101(b) (determined without regard to sec-
tion 3101(c)) or 3201(a) (including amounts 
taken into account under section 3121(v)(2)), 
and 
‘‘(C) wages received from the performance 
of services earned outside the United States for 
a foreign employer.’’. 
(2) NET OPERATING LOSSES NOT TAKEN INTO 
ACCOUNT.—Section 1411(c)(1)(B) of such Code is 
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amended by inserting ‘‘(other than section 172)’’ 
after ‘‘this subtitle’’. 
(3) INCLUSION
OF
CERTAIN
FOREIGN
IN-
COME.— 
(A) IN GENERAL.—Section 1411(c)(1)(A) 
of such Code is amended by striking ‘‘and’’ at 
the end of clause (ii), by striking ‘‘over’’ at the 
end of clause (iii) and inserting ‘‘and’’, and by 
adding at the end the following new clause: 
‘‘(iv) any amount includible in gross 
income under section 951, 951A, 1293, or 
1296, over’’. 
(B) PROPER
TREATMENT
OF
CERTAIN 
PREVIOUSLY TAXED EARNINGS AND PROFITS.— 
Section 1411(c) of such Code is amended by 
adding at the end the following new paragraph: 
‘‘(7) CERTAIN EARNINGS AND PROFITS OF FOR-
EIGN CORPORATIONS.— 
‘‘(A) IN GENERAL.—Except as otherwise 
provided by the Secretary, a distribution of 
earnings and profits that is not treated as a 
dividend for purposes of chapter 1 by reason of 
section 959(d) or section 1293(c) shall not be 
treated as a dividend for purposes of this sec-
tion. 
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‘‘(B) REGULATIONS
AND
OTHER
GUID-
ANCE.—The Secretary shall issue regulations or 
other guidance providing for the treatment of 
distributions by a foreign corporation after De-
cember 31, 2025, of earnings and profits of 
such foreign corporation which accrued before 
such date, but which have not been previously 
subject to tax under this section.’’. 
(d) TRANSFERS OF REVENUES TO OLD-AGE AND 
SURVIVORS, DISABILITY INSURANCE, AND FEDERAL HOS-
PITAL INSURANCE TRUST FUNDS.— 
(1) FEDERAL OLD-AGE AND SURVIVORS TRUST 
FUND.— 
(A) IN GENERAL.—Section 201(a) of the 
Social Security Act (42 U.S.C. 401(a)) is 
amended— 
(i) by striking ‘‘100 per centum of’’, 
(ii) by inserting ‘‘100 percent of’’ be-
fore ‘‘the taxes’’ each place it appears in 
paragraphs (1), (2), (3), and (4), and 
(iii) by striking ‘‘and’’ at the end of 
paragraph (3), by striking the period at 
the end of paragraph (4) and inserting ‘‘; 
and’’, and by inserting after paragraph (4) 
the following new paragraph: 
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‘‘(5) 71.3 percent of the taxes imposed by sec-
tion 1411 of the Internal Revenue Code of 1986 for 
any taxable year beginning after December 31, 
2025, as determined by the Secretary of the Treas-
ury or the Secretary’s delegate based on tax returns 
under subtitle F of such Code, less the amounts 
specified in paragraph (3) of subsection (b).’’. 
(B) 
CONFORMING
AMENDMENT.—The 
fourth sentence of section 201(a) of such Act 
(42 U.S.C. 401(a)) is amended by striking 
‘‘clauses (3) and (4)’’ each place it appears and 
inserting ‘‘paragraphs (3), (4), and (5)’’. 
(2) FEDERAL
DISABILITY
INSURANCE
TRUST 
FUND.—Section 201(b) of the Social Security Act 
(42 U.S.C. 401(b)) is amended— 
(A) by striking ‘‘100 per centum of’’, and 
(B) by striking ‘‘and’’ at the end of para-
graph (1), by striking the period at the end of 
paragraph (2) and inserting ‘‘; and’’, and by in-
serting after paragraph (2) the following new 
paragraph: 
‘‘(3) 10.3 percent of the taxes imposed by sec-
tion 1411 of the Internal Revenue Code of 1986 for 
any taxable year beginning after December 31, 
2025, as determined by the Secretary of the Treas-
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ury or the Secretary’s delegate based on tax returns 
under subtitle F of such Code.’’. 
(3) FEDERAL
HOSPITAL
INSURANCE
TRUST 
FUND.—Section 1817(a) of the Social Security Act 
(42 U.S.C. 1395i(a)) is amended— 
(A) by striking ‘‘100 per centum of’’, 
(B) by inserting ‘‘100 percent of’’ before 
‘‘the taxes’’ each place it appears in paragraphs 
(1) and (2), and 
(C) by striking ‘‘and’’ at the end of para-
graph (1), by striking the period at the end of 
paragraph (2) and inserting ‘‘; and’’, and by in-
serting after paragraph (2) the following new 
paragraph: 
‘‘(3) 28.7 percent of the taxes imposed by sec-
tion 1411 of the Internal Revenue Code of 1986 for 
any taxable year beginning after December 31, 
2025, as determined by the Secretary of the Treas-
ury or the Secretary’s delegate based on tax returns 
under subtitle F of such Code.’’. 
(e) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
December 31, 2025. 
Æ 
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