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.

2/14/2023, 3:15 PM

Summary of Bill HR 2847

Bill 117 hr 2847 aims to make changes to the Internal Revenue Code of 1986 in relation to the limitation on downward attribution of stock ownership when applying constructive ownership rules to controlled foreign corporations. The bill seeks to restore this limitation, which was previously in place but has since been removed.

The purpose of this amendment is to address issues related to the ownership structure of controlled foreign corporations and ensure that the rules governing stock ownership are applied in a fair and consistent manner. By reinstating the limitation on downward attribution of stock ownership, the bill aims to prevent potential abuse of the tax system and ensure that controlled foreign corporations are subject to the appropriate tax regulations.

Overall, the goal of Bill 117 hr 2847 is to strengthen the tax laws related to controlled foreign corporations and promote transparency and fairness in the taxation of these entities. The bill does not appear to have any partisan motivations and is focused on making technical adjustments to the existing tax code for the benefit of the overall tax system.

Congressional Summary of HR 2847

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

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Current Status of Bill HR 2847

Bill HR 2847 is currently in the status of Bill Introduced since April 26, 2021. Bill HR 2847 was introduced during Congress 117 and was introduced to the House on April 26, 2021.  Bill HR 2847's most recent activity was Referred to the House Committee on Ways and Means. as of April 26, 2021

Bipartisan Support of Bill HR 2847

Total Number of Sponsors
1
Democrat Sponsors
1
Republican Sponsors
0
Unaffiliated Sponsors
0
Total Number of Cosponsors
8
Democrat Cosponsors
4
Republican Cosponsors
4
Unaffiliated Cosponsors
0

Policy Area and Potential Impact of Bill HR 2847

Primary Policy Focus

Taxation

Potential Impact Areas

Financial services and investmentsForeign and international corporationsSecuritiesTaxation of foreign incomeU.S. and foreign investments

Alternate Title(s) of Bill HR 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.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.
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Sponsors and Cosponsors of HR 2847

R
Gwen Moore
Wisconsin(Democrat)
R
Bradley Scott Schneider
Illinois(Democrat)
R
Lucy McBath
Georgia(Democrat)
R
A. Drew Ferguson IV
Georgia(Republican)
R
Ron Estes
Kansas(Republican)

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