To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.

[Congressional Bills 119th Congress] [From the U.S. Government Publishing Office] [H.R. 2186 Introduced in House (IH)] <DOC> 119th CONGRESS 1st Session H. R. 2186 To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules. _______________________________________________________________________ IN THE HOUSE OF REPRESENTATIVES March 18, 2025 Mr. Estes (for himself and Ms. Moore of Wisconsin) introduced the following bill; which was referred to the Committee on Ways and Means _______________________________________________________________________ A BILL To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, SECTION 1. RESTORATION OF LIMITATION ON DOWNWARD ATTRIBUTION OF STOCK OWNERSHIP IN APPLYING CONSTRUCTIVE OWNERSHIP RULES. (a) In General.--Section 958(b) of the Internal Revenue Code of 1986 is amended-- (1) by inserting after paragraph (3) the following: ``(4) Subparagraphs (A), (B), and (C) of section 318(a)(3) shall not be applied so as to consider a United States person as owning stock which is owned by a person who is not a United States person.'', and (2) by striking ``Paragraph (1)'' in the last sentence and inserting ``Paragraphs (1) and (4)''. (b) Foreign Controlled United States Shareholders.--Subpart F of part III of subchapter N of chapter 1 of such Code is amended by inserting after section 951A the following new section: ``SEC. 951B. AMOUNTS INCLUDED IN GROSS INCOME OF FOREIGN CONTROLLED UNITED STATES SHAREHOLDERS. ``(a) In General.--In the case of any foreign controlled United States shareholder of a foreign controlled foreign corporation-- ``(1) this subpart (other than sections 951A, 951(b), and 957) shall be applied with respect to such shareholder