do not give rise to a taxable presence under the tax law of the country where the branch is located, and (C) determining whether any entity is not fiscally transparent within the meaning of paragraph (2)(B)(v)(II). . (b) Application of foreign tax credit limitation with respect to foreign branches Section 904(d)(2)(J)(i) is amended— (1) by striking qualified business units (as defined in section 989(a)) in 1 or more foreign countries and inserting foreign branches described in section 904(e)(2)(B)(ii) , and (2) by striking a qualified business unit and inserting a foreign branch . (c) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2024. 5. Repeal of check-the-box rules for certain foreign entities and CFC look-thru rules (a) Check-the-Box rules Paragraph (3) of section 7701(a) of the Internal Revenue Code of 1986 is amended— (1) by striking and , and (2) by inserting after insurance companies the following: , and any foreign business entity that has one or more owners all of which have limited liability. . (b) Look-Thru rule Subparagraph (C) of section 954(c)(6) of such Code is amended to read as follows: (C) Termination Subparagraph (A) shall not apply to dividends, interest, rents, and royalties received or accrued after the date of the enactment of the Corporate Tax Dodging Prevention Act . . (c) Effective date The amendments made by this section shall take effect on the date of the enactment of this Act. 6. Limitation on deduction of interest by domestic corporations which are members of an international financial reporting group (a) In general Section 163 of the Internal Revenue Code of 1986 is amended by redesignating subsection (n) as subsection (o) and by inserting after subsection (m) the following new subsection: (n) Limitation on deduction of interest by domestic corporations in international financial reporting groups (1) In general In the case of any domestic corporation which is a member of any international financial reporting group,