# 119-hr-2186: To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.

119-hr-2186, To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules., is a 119th Congress bill sponsored by Rep. Estes, Ron [R-KS-4] (R-KS); status introduced; PRIA reads it as touching household money (as of 2025-12-21).

- Canonical: https://policyrisk.com/legislation/119-hr-2186
- As of: 2025-12-21
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Bill: 119-hr-2186
- Congress: 119
- Title: To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.
- Status: introduced
- Introduced: 2025-03-18
- Sponsor: Rep. Estes, Ron [R-KS-4] (R-KS)
- Cosponsors: 1
- Policy area: Taxation
- Touches household money: yes
- Last recorded action: 2025-12-21

## 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.

## Cosponsors (1)

- Rep. Moore, Gwen [D-WI-4] (D-WI), 2025-03-18T00:00:00.000Z

## Provisions PRIA read

- Limits on counting foreign-owned stock: benefit, low. 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…
- No retroactive tax rule changes: benefit, low. 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’…
- New rules for U.S. owners of foreign firms: cost, low. 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…

## Related bills

- 119-hr-9877: Health Equity and Accountability Act of 2026
- 119-hr-4669: FEMA Act of 2025
- 119-hr-2725: Affordable Housing Credit Improvement Act of 2025
- 119-hr-6900: American Affordability Act of 2025
- 119-hr-137: TCJA Permanency Act
- 119-hr-33: To amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United…

## Sources
- [119-hr-2186 on Congress.gov](https://www.congress.gov/bill/119th-congress/house-bill/2186)

## Related
- [119-hr-9877: Health Equity and Accountability Act of 2026](https://policyrisk.com/legislation/119-hr-9877)
- [119-hr-4669: FEMA Act of 2025](https://policyrisk.com/legislation/119-hr-4669)
- [119-hr-2725: Affordable Housing Credit Improvement Act of 2025](https://policyrisk.com/legislation/119-hr-2725)
- [119-hr-6900: American Affordability Act of 2025](https://policyrisk.com/legislation/119-hr-6900)
- [119-hr-137: TCJA Permanency Act](https://policyrisk.com/legislation/119-hr-137)
- [119-hr-33: To amend the Internal Revenue Code of 1986 to provide special rules for the tax…](https://policyrisk.com/legislation/119-hr-33)
- [All bills in Congress](https://policyrisk.com/legislation)

Source: PRIA, https://policyrisk.com/legislation/119-hr-2186 (as of 2025-12-21).