Bill > HR2847

This bill aims to amend the Internal Revenue Code to restore the limitation on downward attribution of stock ownership when applying the constructive ownership rules to controlled foreign corporations (CFCs). Specifically, it would prevent a U.S. person from being considered as owning stock owned by a non-U.S. person. The bill also introduces a new section, 951B, which would apply certain subpart F rules (other than sections 951A, 951(b), 957, and 965) to "foreign controlled United States shareholders" of "foreign controlled foreign corporations," treating them similarly to U.S. shareholders of CFCs. The amendments would apply to the last taxable year of foreign corporations beginning before January 1, 2018, and each subsequent taxable year, as well as the taxable years of U.S. persons in which or with which those foreign corporation tax years end.

Budget and Finance

https://www.congress.gov/bill/117th-congress/house-bill/2847/all-info