A parallel set of rules is created for foreign controlled shareholders
To provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70353, Sec. 70353.
Written by .
A parallel set of rules is created for foreign controlled shareholders
The document says “shall”Who acts: Secretary of the TreasuryHow: statuteSec. 70353 in the PDF
What the document says
“In the case of any foreign controlled United States shareholder of a foreign controlled foreign corporation--”
The section adds a new section 951B to subpart F of part III of subchapter N of chapter 1 of the Internal Revenue Code of 1986. For a foreign controlled United States shareholder of a foreign controlled foreign corporation, the subpart other than sections 951A, 951(b) and 957 is applied separately and in addition, reading foreign controlled United States shareholder for United States shareholder and foreign controlled foreign corporation for controlled foreign corporation. Section 951A and any other provisions the Secretary names are applied by reading their references to a United States shareholder and to a controlled foreign corporation as including these.
What the document actually says
“In the case of any foreign controlled United States shareholder of a foreign controlled foreign corporation--”
That sentence, in plain words
The rules that follow cover one kind of holder. That holder is based here but run from abroad. It must hold a foreign firm that is also run from abroad.
What this is about
The usual subpart is run twice for such a holder. The second run swaps in the new terms. That brings in firms the bar above shut out.
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 parallel set of rules is created for foreign controlled shareholders,” 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-new-section/ (retrieved October 10, 2026).
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