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S. 2589 116th Congress Senate

A bill to amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations,…

Official title: A bill to amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership r… Show full official titleShow less

Official title: A bill to amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations, and for other purposes.

Introduced: September 26, 2019 See on congress.gov
Taxation Financial services and investmentsForeign and international corporationsSecuritiesTaxation of foreign incomeU.S. and foreign investments
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This bill died when the 116th Congress ended
It never became law before the 116th Congress (2019–2020) adjourned, and bills don't carry over to the next Congress. It would have to be reintroduced. You can still save it for reference, but it won't receive updates.
 Everywhere this bill has been 2 steps
Introduced
In committee
Reported out
Passed House
Passed Senate
To President
Became law
Sep 26, 2019
Introduced in Senate
Sep 26, 2019
Read twice and referred to the Committee on Finance.
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 Latest action September 26, 2019

Read twice and referred to the Committee on Finance.

 Plain-English summary Congressional Research Service

This bill amends the Internal Revenue Code to limit the scope of downward attribution rules to 50% of stock ownership in applying constructive ownership rules to controlled foreign corporations.

 Related & companion bills 2
  • HR 4509 Identical bill To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in appl…
  • S 3548 CARES Act
 Bill text 1 version

Source documents hosted by congress.gov.

 Committees of jurisdiction 1
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APA
U.S. Congress. (2026). S. 2589: A bill to amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations, and for other purposes.. 116th Congress. Open America. https://openamerica.io/bill/116-S-2589/
MLA
"S. 2589: A bill to amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations, and for other purposes.." 116th Congress, 2026, Open America, https://openamerica.io/bill/116-S-2589/.
Bluebook (legal)
S. 2589, 116th Cong. (2026), https://openamerica.io/bill/116-S-2589/.
Markdown link
[S. 2589: A bill to amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations, and for other purposes.](https://openamerica.io/bill/116-S-2589/)
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