“the term `foreign controlled United States shareholder' means, with respect to any foreign corporation, any United States person which would be a United States shareholder with respect to such foreign corporation if--”
The section defines a foreign controlled United States shareholder as any United States person that would be a United States shareholder of the foreign corporation if section 951(b) were read as saying more than 50 percent in place of 10 percent or more, and section 958(b) were read without the new paragraph (4).
What the document actually says
“the term `foreign controlled United States shareholder' means, with respect to any foreign corporation, any United States person which would be a United States shareholder with respect to such foreign corporation if--”
That sentence, in plain words
The term covers a United States person holding a foreign firm. That person must meet the tests that follow.
What this is about
One test raises the holding line to more than half. The other ignores the new bar. So the term reaches only large holders.
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 foreign controlled United States shareholder is defined by a 50 percent test,” 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-shareholder-definition/ (retrieved October 10, 2026).
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