Ron Estes (R-KS)
To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.
A Republican bill with 1 Democratic cosponsor · See the cosponsor
Last activity — Referred to the House Committee on Ways and Means.
In committee
Introduced and handed to a committee in the chamber it started in.
The committee holds it, and most bills are never heard from again. A hearing or a committee vote would be news; silence is the usual outcome, and it kills the bill without anyone voting against it.
Its path through Congress
- 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
- Scored +1
Does this reduce what the federal government owes?
By closing tax avoidance loopholes, the bill potentially increases federal revenue.
- Scored +1
Does this make the government pay for what it commits to?
The bill aims to prevent tax avoidance through stricter attribution rules.
- Scored +1
Does this give the federal government more power?
The bill expands federal tax authority over certain foreign-controlled structures.
The opposite· 3 of 7
- Scored -5
Would the very wealthiest people be better off under this?
The bill restricts specific tax avoidance mechanisms used by ultra-high net worth individuals.
- Scored -5
Would billionaires be better off under this?
The bill implements stricter attribution rules to prevent tax avoidance by very large entities.
- Scored -4
Would people with substantial wealth be better off under this?
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)).
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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
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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. Tap or hover a score for the reason it gave.
- Demographic And Interest Groups
- Would billionaires be better off under this? — The bill implements stricter attribution rules to prevent tax avoidance by very large entities. Would the very wealthiest people be better off under this? — The bill restricts specific tax avoidance mechanisms used by ultra-high net worth individuals. Would people with substantial wealth be better off under this? — New taxation rules on foreign controlled entities may negatively impact high net worth individuals. Would high-income households be better off under this? — The bill targets tax structures often used by high-income households with foreign interests. Would business owners be better off under this? — The bill imposes new tax inclusion rules on certain foreign-controlled business entities.
- Economy And Finance
- Does this make the government pay for what it commits to? — The bill aims to prevent tax avoidance through stricter attribution rules. Does this reduce what the federal government owes? — By closing tax avoidance loopholes, the bill potentially increases federal revenue. Does this raise taxes on the highest earners? — The changes target specific shareholder structures often utilized by high-net-worth individuals and large entities. Does this raise the taxes companies pay? — The bill introduces new tax inclusions for foreign controlled foreign corporations and their shareholders.
- Governance And Ideology
- Does this give the federal government more power? — The bill expands federal tax authority over certain foreign-controlled structures.
- 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