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Introduced

HB5751: To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.

: Drew Ferguson (R-US) : May 25, 2026 Updated: Sep 27, 2023
Taxation
Bill ProgressIntroduced
  1. 1Introduced (current step)
  2. 2Passed One Chamber
  3. 3Passed Both Chambers
  4. 4Became Law

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Bill information

Summary

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

Plain-language summary

This bill would change how the Internal Revenue Code counts stock ownership for tax purposes, specifically restoring a limitation on 'downward attribution' rules. Downward attribution refers to treating a parent company's stock ownership as if their subsidiaries or children own it for tax calculation purposes. The bill aims to narrow when the IRS can use this ownership counting method. It was recently introduced in Congress and is currently in the early stages of the legislative process.

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HB5751: To amend the Internal Revenue Code of 1986 to restore the limitation on downwar…

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