To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.
This bill restores the limitation on downward attribution rules to 50% of stock ownership in applying constructive ownership rules to controlled foreign corporations.
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Timeline
Introduced in House
Referred to the House Committee on Ways and Means.
Introduced in House
Referred to the House Committee on Ways and Means.
Taxation
To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.
USA118th CongressHR-5751| House
| Updated: 9/27/2023
This bill restores the limitation on downward attribution rules to 50% of stock ownership in applying constructive ownership rules to controlled foreign corporations.