A holder on any day of the year counts for subpart F income
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”
A holder counts if they held shares on any day of the year. That holder must count a share of the firm's income.
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.
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