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.

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.