Instructions for Form 8991, December 2025 revision, clarification under the heading Expenditures charged to capital account

In the December 2025 revision of the Instructions for Form 8991, the second sentence under Expenditures charged to capital account, under Reminders, is being revised to improve clarity. The revised sentence is as follows. “The base erosion tax benefit in a tax year with respect to that expenditure is the amount of allowed amortization or deduction for the tax year.”