of inventory determined solely on basis of production activities (a) In general Section 863(b) is amended by adding at the end the following: Gains, profits, and income from the sale or exchange of inventory property described in paragraph (2) shall be allocated and apportioned between sources within and without the United States solely on the basis of the production activities with respect to the property. . (b) Effective date The amendment made by this section shall apply to taxable years beginning after December 31, 2017. II Inbound transactions 14401. Base erosion and anti-abuse tax (a) Imposition of tax Subchapter A of chapter 1 is amended by adding at the end the following new part: VII Base erosion and anti-abuse tax Sec. 59A. Tax on base erosion payments of taxpayers with substantial gross receipts. 59A. Tax on base erosion payments of taxpayers with substantial gross receipts (a) Imposition of tax There is hereby imposed on each applicable taxpayer for any taxable year a tax equal to the base erosion minimum tax amount for the taxable year. Such tax shall be in addition to any other tax imposed by this subtitle. (b) Base erosion minimum tax amount For purposes of this section— (1) In general Except as provided in paragraph (2), the term base erosion minimum tax amount means, with respect to any applicable taxpayer for any taxable year, the excess (if any) of— (A) an amount equal to 10 percent of the modified taxable income of such taxpayer for the taxable year, over (B) an amount equal to the regular tax liability (as defined in section 26(b)) of the taxpayer for the taxable year, reduced (but not below zero) by the excess (if any) of— (i) the credits allowed under this chapter against such regular tax liability, over (ii) the credit allowed under section 38 for the taxable year which is properly allocable to the research credit determined under section 41(a). (2) Modifications for taxable years beginning after 2025 In the case of any taxable year beginning after December 31, 2025, paragraph (1) shall