Bill > HR5751

This bill amends the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership when applying constructive ownership rules. Specifically, it provides that certain provisions of the code that attribute stock ownership from a non-U.S. person to a U.S. person shall not apply. The bill also creates a new section 951B that requires "foreign controlled United States shareholders" of "foreign controlled foreign corporations" to include certain amounts in their gross income, even if they would not otherwise be considered a U.S. shareholder under the code. The amendments made by this bill apply to the last taxable year of foreign corporations beginning before January 1, 2023, and subsequent years, as well as the corresponding taxable years of the affected U.S. persons.