which is outside of such foreign country and— (A) the profits of which are subject to a combined aggregate effective rate of tax in such foreign country and the country of the permanent establishment that is less than the lesser of— (i) 15 percent, or (ii) 60 percent of the general statutory rate of tax on income on corporations in such foreign country, or (B) which is located in a foreign country with which the United States does not have an income tax treaty and is not taxed by the foreign country which is a party to the treaty. . (c) Effective date The amendments made by this section shall apply to payments made after the date of the enactment of this Act. (d) Special rule for treaties Notwithstanding sections 894 or 7852(d) of the Internal Revenue Code of 1986, the amendments made by this section shall apply without regard to any treaty obligation of the United States. 12. Repeal of deduction for foreign-derived intangible income (a) In general Part VIII of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by striking section 250 (and the item related to such section in the table of sections for such part). (b) Conforming amendments (1) Section 172(d) of the Internal Revenue Code of 1986 is amended by striking paragraph (9). (2) Section 246(b) of such Code is amended— (A) by striking the comma after section 243(a)(1) the first place it appears and inserting and and by striking and section 250 , and (B) by inserting and after section 243(a)(1) the second place it appears and by striking , and 250 . (c) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2024.