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.
Jurisdiction
US Congress
Session
119th Congress (2025-2026)
Last updated at
Jun 13, 2026, 4:10 PM
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Sign in to take action- Introduced
- Passed House
- Passed Senate
- To President
- Became Law
Bill overview
This bill amends the Internal Revenue Code to restore a limitation on how stock ownership is attributed when determining if a U.S. person is considered an owner of a foreign corporation. Specifically, it clarifies rules regarding ‘constructive ownership’ for both U.S. shareholders of foreign corporations and foreign corporations with U.S. shareholders. The changes aim to prevent the misclassification of shareholders and ensure accurate tax treatment of foreign-controlled businesses.
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