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H.R. 2847 117th Congress House

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…

Official title: 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… Show full official titleShow less

Official title: 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: April 26, 2021 Introduced by: Gwen Moore Democratic · Wisconsin 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 117th Congress ended
It never became law before the 117th Congress (2021–2022) 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
Apr 26, 2021
Referred to the House Committee on Ways and Means.
Apr 26, 2021
Introduced in House
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 Latest action April 26, 2021

Referred to the House Committee on Ways and Means.

 Plain-English summary Congressional Research Service

This bill restores the limitation on downward attribution rules to 50% of stock ownership in applying constructive ownership rules to controlled foreign corporations.

 Related & companion bills 2
  • HR 5376 An act to provide for reconciliation pursuant to title II of S. Con. Res. 14.
  • S 5349 International Competition for American Jobs Act
 Bill text 1 version

Source documents hosted by congress.gov.

 Committees of jurisdiction 1
 Cosponsors 4
All 4 Democratic 2 Republican 1
D
McBath, Lucy
Georgia · May 11, 2021
 R
Estes, Ron
Kansas · Apr 26, 2021
Ferguson, A.
· Apr 26, 2021
 D
Schneider, Bradley Scott
Illinois · Apr 26, 2021
Cite this page click to expand
APA
U.S. Congress. (2026). H.R. 2847: 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.. 117th Congress. Open America. https://openamerica.io/bill/117-HR-2847/
MLA
"H.R. 2847: 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.." 117th Congress, 2026, Open America, https://openamerica.io/bill/117-HR-2847/.
Bluebook (legal)
H.R. 2847, 117th Cong. (2026), https://openamerica.io/bill/117-HR-2847/.
Markdown link
[H.R. 2847: 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/117-HR-2847/)
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