RepublicanBill · 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.

Rep. Estes
Age: 70 years
Kansas
Introduced
3/18/2025
Last activity
3/18/2025 — Referred to the House Committee on Ways and Means.
Sponsored by
Ron Estes
Cosponsors
Republican - 0Democrat - 1
Taxation
  1. Introduced
  2. 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.