end the following new subsection: (e) Special application of subpart (1) In general For taxable years beginning after December 31, 2024, notwithstanding any other provision of this subpart, the term subpart F income means, in the case of any controlled foreign corporation, the income of such corporation derived from any foreign country. (2) Applicable rules Rules similar to the rules under the last sentence of subsection (a) and subsection (d) shall apply to this subsection. . (b) Treatment of previously deferred foreign income (1) Treatment of interest Section 965(h) of the Internal Revenue Code of 1986 is amended by adding at the end the following new paragraph: (7) Rules relating to interest In the case of any amount of the net tax liability prorated to an installment under this subsection which has not been paid before the date of the enactment of this paragraph, the last date prescribed for payment of any such installment for purposes of section 6601 shall be the earlier of such last date (determined without regard to this paragraph) or such date of enactment. . (2) Rules for S corporations Section 965(i)(2)(A) of such Code is amended by adding at the end the following new clause: (iv) The date of the enactment of the Corporate Tax Dodging Prevention Act . . (c) Effective date The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2024, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end. 4. Country-by-country application of limitation on foreign tax credit based on taxable units (a) In general Section 904 is amended by inserting after subsection (d) the following new subsection: (e) Country-by-Country application of section based on taxable units (1) In general The provisions of subsections (a), (b), (c), and (d) and sections 907 and 960 shall be applied separately with respect to each country and possession by taking into account the aggregate items properly attributable or