A holder on any day of the year counts for subpart F income
To provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70354, Sec. 70354.
Written by .
A holder on any day of the year counts for subpart F income
The document says “shall”Who acts: Secretary of the TreasuryHow: statuteSec. 70354 in the PDF
What the document says
“each United States shareholder which owns (within the meaning of section 958(a)) stock in such corporation on any day during the CFC year shall include in gross income such shareholder's pro rata share”
The section rewrites subsection (a) of section 951 of the Internal Revenue Code of 1986. Where a foreign corporation is a controlled foreign corporation at any time in its taxable year, each United States shareholder owning stock in it on any day of that year counts its pro rata share of the corporation's subpart F income, and each shareholder owning stock on the last day of that year on which the corporation is a controlled foreign corporation counts the amount worked out under section 956, so far as not excluded under section 959(a)(2).
What the document actually says
“each United States shareholder which owns (within the meaning of section 958(a)) stock in such corporation on any day during the CFC year shall include in gross income such shareholder's pro rata share”
That sentence, in plain words
A holder counts if they held shares on any day of the year. That holder must count a share of the firm's income.
What this is about
The year is the one when the firm was foreign controlled. A second rule uses the last such day. That one covers a different amount.
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. 70354, 139 Stat. 210 (2025). https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
This page
“A holder on any day of the year counts for subpart F income,” Provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70354, Sec. 70354. Read the Mandate, https://readthemandate.org/pl-119-21/proposal/sec70354-inclusion/ (retrieved October 10, 2026).
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