PRIA Logo™
119-hr-2186119th CongressWALLET

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

Sponsored By: Representative Estes, Ron [R-KS-4]

Introduced

Summary

Restores the limitation on downward attribution of stock ownership and creates a new Subpart F rule for foreign-controlled U.S. shareholders. This bill would narrow when U.S. persons are treated as owning stock through foreign ties and add Section 951B to bring certain foreign-controlled U.S. shareholders into Subpart F income rules.

Personalized for You

How does this bill affect your finances?

Personalize government policy and PRIA will tell you what this bill means for your household, plus every other piece of legislation we track. PRIA reads each provision against your financial profile to show you exactly what matters to your wallet.

Free to download

Bill Overview

Analyzed Economic Effects

3 provisions identified: 2 benefits, 1 costs, 0 mixed.

Limits on counting foreign-owned stock

If enacted, this would stop counting stock owned by a non‑U.S. person as owned by a U.S. person through certain links. That change would reduce cases where Americans are treated as owning foreign stock for anti‑deferral tax rules. It would start with the last tax year of a foreign corporation that begins before January 1, 2025, and the related U.S. owners’ tax years. If you have foreign interests, this could lower your U.S. tax exposure in some cases.

No retroactive tax rule changes

If enacted, these changes would not be used to read earlier tax years. You would not be able to use this bill to argue how older years should have worked. The effective date would start with the last tax year of a foreign corporation that begins before January 1, 2025, and the related U.S. owners’ tax years.

New rules for U.S. owners of foreign firms

If enacted, this would create new categories for U.S. owners controlled by foreign groups and apply anti‑deferral tax rules to them. It would use a "more than 50%" ownership test to decide who is covered. These rules would apply in addition to the existing ones, and the rule that taxes some foreign profits would also apply. Treasury would issue guidance and anti‑avoidance rules. This would start with the last tax year of a foreign corporation that begins before January 1, 2025, and the related U.S. owners’ tax years. If you own a foreign company, this could lead to more of its profits being taxed to you.

Sponsors & CoSponsors

Sponsor

Estes, Ron [R-KS-4]

KS • R

Cosponsors

  • Rep. Moore, Gwen [D-WI-4]

    WI • D

    Sponsored 3/18/2025

Roll Call Votes

No roll call votes available for this bill.

View on Congress.gov
Back to Legislation