Bill · H.R. 2186· House(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.
- Introduced
- 3/18/2025
- Last activity
- 3/18/2025 — Referred to the House Committee on Ways and Means.
- Sponsored by
- Ron Estes
- Cosponsors
- - 0 - 1
- Introduced
- In Committee
What this bill would do
This bill aims to amend the Internal Revenue Code of 1986 to restore a specific limitation on downward attribution of stock ownership. It introduces rules regarding "foreign controlled United States shareholders" and "foreign controlled foreign corporations." The legislation modifies how stock ownership is considered when applying constructive ownership rules. Additionally, it instructs the Secretary to create regulations to carry out these new provisions and prevent avoidance of the section. These changes are set to apply to specific taxable years beginning before or after January 1, 2025.
Yes
Does this reduce what the federal government owes?+1
By closing tax avoidance loopholes, the bill potentially increases federal revenue.
Does this make the government pay for what it commits to?+1
The bill aims to prevent tax avoidance through stricter attribution rules.
Does this give the federal government more power?+1
The bill expands federal tax authority over certain foreign-controlled structures.
The opposite· 3 of 7
Would the very wealthiest people be better off under this?-5
The bill restricts specific tax avoidance mechanisms used by ultra-high net worth individuals.
Would billionaires be better off under this?-5
The bill implements stricter attribution rules to prevent tax avoidance by very large entities.
Would people with substantial wealth be better off under this?-4
New taxation rules on foreign controlled entities may negatively impact high net worth individuals.
Who it would affect, and how
Potential Positive Impacts for People
-
Restoration of limitations on stock ownership: By amending Section 958(b), the bill prevents a United States person from being considered as owning stock owned by a person who is not a United States person (Section 1(a)).
-
Prevention of avoidance: The bill authorizes the Secretary to prescribe regulations or guidance intended to prevent the avoidance of the purposes of the new section (Section 1(b)(d)(2)).
Potential Negative Impacts for People
-
New tax inclusions for specific shareholders: The bill creates a new section, 951B, which includes certain amounts in the gross income of "foreign controlled United States shareholders" (Section 1(b)).
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Changes to shareholder definitions: The bill redefines how shareholders and corporations are treated for certain purposes, which may impact how a "foreign controlled United States shareholder" or a "foreign controlled foreign corporation" is treated under the law (Section 1(b)(b) and 1(b)(c)).
Groups and Interests Ranking
Every group the model scored this bill for, from -10 to +10. Hover a score for the reason it gave.
- Demographic And Interest Groups
- Good For Billionaires-5Good For Ultra High Net Worth Individuals-5Good For High Net Worth Individuals-4Good For High Income Households-3Good For Business Owners-2
- Economy And Finance
- Improves Fiscal Responsibility+1Reduces National Debt+1Increases Wealthy Taxes-4Increases Corporate Taxes-3
- Governance And Ideology
- Increases Federal Power+1
- 3/18/2025
- Referred to the House Committee on Ways and Means.
- 1 Cosponsor added.
- Introduced in House
2 bills Congress.gov lists as related to this one — companions in the other chamber, earlier versions, and bills this one absorbed or was folded into.
Gwen MooreDemocrat · Wisconsin