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

What the bill does: This bill amends the U.S. tax code to restore limits on "downward attribution" of stock ownership, preventing stock owned by non-U.S. persons from being attributed to U.S. persons under constructive ownership rules (Section 958(b)). It also adds a new Section 951B, which imposes Subpart F and GILTI tax rules on "foreign controlled United States...