The amount is counted in the year holding the last day of ownership
To provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70354, Sec. 70354.
Written by .
The amount is counted in the year holding the last day of ownership
The document says “shall”Who acts: Secretary of the TreasuryHow: statuteSec. 70354 in the PDF
What the document says
“Any amount required to be included in gross income by a United States shareholder under paragraph (1) with respect to a CFC year shall be included in gross income for the shareholder's taxable year which includes the last day on which the shareholder owns (within the meaning of section 958(a)) stock in the controlled foreign corporation during such CFC year.”
The section provides that an amount a United States shareholder must count for a CFC year goes into gross income for the shareholder's taxable year that includes the last day of that CFC year on which the shareholder owned stock in the corporation.
What the document actually says
“Any amount required to be included in gross income by a United States shareholder under paragraph (1) with respect to a CFC year shall be included in gross income for the shareholder's taxable year which includes the last day on which the shareholder owns (within the meaning of section 958(a)) stock in the controlled foreign corporation during such CFC year.”
That sentence, in plain words
The amount goes into one tax year of the holder. That is the year holding the last day the holder owned the shares.
What this is about
That day falls inside the firm's own tax year. The holder's year may differ from the firm's. This rule ties the two together.
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 amount is counted in the year holding the last day of ownership,” 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-year-of-inclusion/ (retrieved October 10, 2026).
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