1. Short title This Act may be cited as the Ending Tax Breaks for Massive Sovereign Wealth Funds Act . 2. Investment income of certain foreign governments subject to tax (a) In general Section 892(a) of the Internal Revenue Code of 1986 is amended by adding at the end the following new paragraph: (4) Investment income of non-exempt foreign governments (A) In general Paragraph (1)(A)(i) shall not apply to income from investments of a non-exempt foreign government. (B) Non-exempt foreign government For purposes of this paragraph, the term non-exempt foreign government means any foreign government which— (i) holds, directly or indirectly, more than $100,000,000,000 in assets for investment or for the production of income, and (ii) either— (I) does not have a free trade agreement in effect with the United States or an income tax treaty or convention in effect with the United States, or (II) is a foreign government of a covered nation (as defined in section 4872(d)(2) of title 10, United States Code). . (b) Regulations Section 892(c) of the Internal Revenue Code of 1986 is amended by inserting before the period at the end the following , including— (1) regulations to prevent the avoidance of the purposes of subsection (a)(4), and (2) regulations relating to the types of assets taken into account under subsection (a)(4)(B)(i). . (c) Publication of list of non-Exempt foreign governments (1) In general Not later than December 31, 2024, the Secretary of the Treasury (or the Secretary's delegate) shall publish a list of foreign governments which are non-exempt foreign governments (as defined in section 892(a)(4) of the Internal Revenue Code of 1986, as added by this section). (2) Updating The Secretary of the Treasury (or the Secretary's delegate) shall regularly update the list published under paragraph (1). (d) Effective date (1) In general Except as provided in paragraph (2), the amendments made by this section shall apply to income received after December 31, 2023. (2) Delay in application for income on qualified