A United States person is not treated as owning a foreign person's stock
To provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70353, Sec. 70353.
Written by .
A United States person is not treated as owning a foreign person's stock
The document says “shall not”Who acts: Secretary of the TreasuryHow: statuteSec. 70353 in the PDF
What the document says
“Subparagraphs (A), (B), and (C) of section 318(a)(3) shall not be applied so as to consider a United States person as owning stock which is owned by a person who is not a United States person.”
The section inserts a new paragraph (4) into section 958(b) of the Internal Revenue Code of 1986 barring subparagraphs (A), (B) and (C) of section 318(a)(3) from being applied so as to treat a United States person as owning stock owned by a person who is not a United States person, and changes the last sentence of section 958(b) to name paragraphs (1) and (4).
What the document actually says
“Subparagraphs (A), (B), and (C) of section 318(a)(3) shall not be applied so as to consider a United States person as owning stock which is owned by a person who is not a United States person.”
That sentence, in plain words
Three parts of an ownership rule are switched off in one case. They may not treat a United States person as owning a foreign person's shares.
What this is about
That kind of treatment is called downward attribution. It pulled foreign firms into United States tax rules. This bar shuts that route.
No action is recorded against this proposal. That is not evidence that none has been taken, and nobody has yet read it against the record. See what the tracker does not yet cover.
Provide for reconciliation pursuant to title II of H. Con. Res. 14, Public Law 119-21, sec. 70353, 139 Stat. 209 (2025). https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
This page
“A United States person is not treated as owning a foreign person's stock,” Provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70353, Sec. 70353. Read the Mandate, https://readthemandate.org/pl-119-21/proposal/sec70353-downward-attribution/ (retrieved October 10, 2026).
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