§951B Amounts Included in Gross Income of Foreign Controlled United States Shareholders

Summary

Makes most of the tax rules for U.S. owners of foreign companies also apply, separately, to U.S. people who control foreign corporations and to foreign companies that would be controlled if those people counted. It does this by swapping the usual terms for "foreign controlled United States shareholder" and "foreign controlled foreign corporation," and it also applies an extra anti‑avoidance rule so those people and companies are included. Definitions: foreign controlled United States shareholder — a U.S. person who would count as a U.S. shareholder if the ownership test used "more than 50 percent" instead of "10 percent or more" and one ownership attribution rule were ignored. foreign controlled foreign corporation — a foreign company that is not a controlled foreign corporation now but would be one if the test used foreign controlled United States shareholders and that same ownership-rule change. The Treasury must write rules to carry this out, including treating these people or companies as U.S. shareholders or controlled foreign corporations for other tax rules and for PFIC rules.