The share follows the stock held and the days it was held
To provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70354, Sec. 70354.
Written by .
The share follows the stock held and the days it was held
The document says “shall”Who acts: Secretary of the TreasuryHow: statuteSec. 70354 in the PDF
What the document says
“A United States shareholder's pro rata share of a controlled foreign corporation's subpart F income for a CFC year shall be the portion of such income which is attributable to--”
The section works out the share as the portion of the income attributable to the stock owned by the shareholder and to any period of the year during which the shareholder owned that stock, was a United States shareholder of the corporation, and the corporation was a controlled foreign corporation.
What the document actually says
“A United States shareholder's pro rata share of a controlled foreign corporation's subpart F income for a CFC year shall be the portion of such income which is attributable to--”
That sentence, in plain words
The share is the part of the income tied to two things. Those two things follow below.
What this is about
One is the stock the holder owned. The other is the days it was held. All three tests must hold at once for a day to count.
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
“The share follows the stock held and the days it was held,” 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-pro-rata/ (retrieved August 26, 2026).
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