To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.

This bill amends the Internal Revenue Code of 1986 to modify the application of constructive stock ownership rules, particularly concerning international taxation. It restores a limitation on downward attribution , specifying that certain constructive ownership rules (Section 318(a)(3)) will not cause a United States person to be considered as owning stock held by a person who is not a United States person. This change aims to prevent unintended tax consequences arising from the attribution of foreign-owned stock to U.S. individuals or entities. Concurrently, the bill introduces a new section, 951B, to address "foreign controlled United States shareholders" and "foreign controlled foreign corporations." This new provision ensures that Subpart F and Global Intangible Low-Taxed Income (GILTI) rules continue to apply to U.S. persons who own more than 50 percent of a foreign corporation, even if they might not otherwise meet the definition of a "United States shareholder" due to the modified attribution rules. The new section redefines how these international tax provisions are applied to such entities, effectively broadening their scope in specific scenarios. The Secretary of the Treasury is authorized to issue regulations to implement these changes and prevent avoidance, with the amendments generally applying to taxable years beginning before January 1, 2025, and subsequent years.