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 changes federal tax rules about when you are treated as owning stock that you don’t hold directly. It restores a limit on “downward attribution,” which is when stock owned by a related person or company is counted as yours under constructive ownership rules. It also adds a new section on what income must be counted by “foreign‑controlled United States shareholders”.

Key points:

• Who is affected: U.S. shareholders with ties to foreign owners or related companies.
• What changes: Brings back a limit on counting someone else’s shares as yours and adds rules for income of foreign‑controlled U.S. shareholders.
• When: The provided text does not state timing details.

Introduced March 18, 2025 by Ron Estes · Last progress March 18, 2025