Bill > S2589

This bill amends the Internal Revenue Code to limit the scope of downward attribution rules to 50% of stock ownership in applying constructive ownership rules to controlled foreign corporations. The bill introduces a new section, 951B, which applies special rules for "foreign controlled United States shareholders" and "foreign controlled foreign corporations" to ensure that certain provisions under Subpart F are applied appropriately to these entities. The amendments made by this bill would apply to the last taxable year of foreign corporations beginning before January 1, 2018, and each subsequent taxable year, as well as to the taxable years of United States persons in which or with which such taxable years of foreign corporations end.

Budget and Finance

https://www.congress.gov/bill/116th-congress/senate-bill/2589/all-info