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

[AI summary unavailable — showing source text] [Congressional Bills 119th Congress] [From the U.S. Government Publishing Office] [H.R. 2186 Introduced in House (IH)] <DOC> 119th CONGRESS 1st Session H. R. 2186 To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules. _______________________________________________________________________ IN THE HOUSE OF REPRESENTATIVES March 18, 2025 Mr. Estes (for himself and Ms. Moore of Wisconsin) introduced the following bill; which was referred to the Committee on Ways and Means _______________________________________________________________________ A BILL To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, SECTION 1. RESTORATION OF LIMITATION ON DOWNWARD ATTRIBUTION OF STOCK OWNERSHIP IN APPLYING CONSTRUCTIVE OWNERSHIP RULES. (a) In General.--Section 958(b) of the Internal Revenue Code of 1986 is amended-- (1) by inserting after paragraph (3) the following: ``(4) Subparagraphs (…