or indirectly) consist primarily of assets being managed on behalf of investors, and (ii) decisions about how to invest the assets are made in the United States. . (b) Effective date The amendments made by this section shall apply to taxable years beginning on or after the date which is 2 years after the date of the enactment of this Act. 9. Modifications to base erosion and anti-abuse tax (a) Acceleration of modifications Section 59A(b) of the Internal Revenue Code of 1986 is amended— (1) in paragraph (1)(A), by striking 10 percent (5 percent in the case of taxable years beginning in calendar year 2018) and inserting 12.5 percent , (2) in paragraph (1)(B), by striking by the excess of and all that follows and inserting by the aggregate amount of the credits allowed under this chapter against such regular tax liability. , (3) by striking paragraphs (2) and (4) and redesignating paragraph (3) as paragraph (2), and (4) in paragraph (2)(A) (as so redesignated), by striking paragraphs (1)(A) and (2)(A) shall each and inserting paragraph (1)(A) shall . (b) Modifications to definition of applicable taxpayer Section 59A(e)(1) of the Internal Revenue Code of 1986 is amended— (1) by striking $500,000,000 in subparagraph (B) and inserting $25,000,000 , and (2) by inserting and at the end of subparagraph (A), by striking , and at the end of subparagraph (B) and inserting a period, and by striking subparagraph (C). (c) Exceptions to definition of base erosion payment Section 59A(d) of the Internal Revenue Code of 1986 is amended by adding at the end the following new paragraph: (6) Exception for certain payments includible in gross income of payee (A) In general Paragraph (1) shall not apply to any portion of an amount— (i) which is paid or accrued by the taxpayer to a foreign person who is a member of the same controlled group of corporations as the taxpayer, and (ii) which— (I) is treated by the foreign person as an amount of income from sources within the United States which is effectively connected with the conduct by