Bill > HR4509

This bill amends the Internal Revenue Code of 1986 to limit the scope of downward attribution rules to 50% of stock ownership when applying constructive ownership rules to controlled foreign corporations. The bill creates a new provision, Section 951B, which applies the subpart F rules (other than certain specified sections) to "foreign controlled United States shareholders" of "foreign controlled foreign corporations" by substituting those terms for the existing "United States shareholder" and "controlled foreign corporation" terminology. This is intended to prevent the avoidance of the purposes of the new section through the use of ownership thresholds below 50%. The amendments made by the bill are effective for the last taxable year of foreign corporations beginning before January 1, 2018, and each subsequent taxable year, as well as 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/house-bill/4509/all-info