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Provide for reconciliation pursuant to title II of H. Con. Res. 14Section 70353 › Proposal

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 notWho 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.”

To provide for reconciliation pursuant to title II of H. Con. Res. 14, Sec. 70353

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.”

To provide for reconciliation pursuant to title II of H. Con. Res. 14, Sec. 70353
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.

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