arrow_back Back to App

Tax Law Changes: Stock Ownership and Foreign Corporations

This bill amends the Internal Revenue Code regarding the attribution of stock ownership, particularly for foreign corporations. It aims to clarify who is considered the owner of stock, potentially impacting tax obligations for individuals and companies with interests in foreign entities. Citizens holding such interests should be aware of potential changes in how their income is reported.
Key points
Limitation on stock ownership attribution: New rules make it harder to attribute stock ownership to a U.S. person if the stock is owned by a non-U.S. person.
New rules for foreign corporations: Definitions and rules for "foreign controlled United States shareholders" and "foreign controlled foreign corporations" are introduced, potentially affecting their taxation.
Impact on income: Changes may result in additional amounts being included in the gross income of U.S. shareholders with interests in foreign corporations.
Effective date: The amendments apply to taxable years of foreign corporations beginning before January 1, 2023, and subsequent years.
article Official text account_balance Process page
Expired
Citizen Poll
No votes cast
Additional Information
Print number: 118_HR_5751
Sponsor: Rep. Ferguson, A. Drew, IV [R-GA-3]
Process start date: 2023-09-27
Lustra uses Artificial Intelligence. Verify details in source documents.
Summarized by: gemini-2.5-flash-preview-05-20
Source data: api.congress.gov
AI work logs for this document launch

OFFICIAL LEGAL TITLE

To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.

FREQUENTLY ASKED QUESTIONS

What is the official ID of this bill?

The official print number for this legislation is 118_HR_5751.

Which chamber initiated this legislation?

This legislation was initiated in the House of Representatives.

When did the legislative process begin?

The process officially started on 2023-09-27.

What are the main provisions?

Key points include:

  • Limitation on stock ownership attribution: New rules make it harder to attribute stock ownership to a U.S. person if the stock is owned by a non-U.S. person.
  • New rules for foreign corporations: Definitions and rules for "foreign controlled United States shareholders" and "foreign controlled foreign corporations" are introduced, potentially affecting their taxation.
  • Impact on income: Changes may result in additional amounts being included in the gross income of U.S. shareholders with interests in foreign corporations.
  • Effective date: The amendments apply to taxable years of foreign corporations beginning before January 1, 2023, and subsequent years.
What is the specific legal status?

The current status is Expired.

Where can I read the full text of this legislation?

The full official text is available at: View full text

Who is the primary sponsor?

The primary sponsor is Rep. Ferguson, A. Drew, IV [R-GA-3].

What is the latest detailed status?

The latest detailed status is: Referred to the House Committee on Ways and Means.

Is this summary verified?

Yes. This content was analyzed by AI and verified by the Lustra Judge System on 2025-12-25.

CATEGORIES

Taxes Economy