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

Bill 119 HR 2186 aims to make changes to the Internal Revenue Code of 1986 regarding the limitation on downward attribution of stock ownership when applying constructive ownership rules. The bill seeks to restore this limitation, which was previously in place but has since been removed.

The purpose of this amendment is to ensure that the rules governing the attribution of stock ownership are applied consistently and fairly. By reinstating the limitation on downward attribution, the bill aims to prevent individuals from using complex ownership structures to avoid tax obligations or manipulate the tax system.

Overall, the goal of Bill 119 HR 2186 is to promote transparency and fairness in the application of tax laws related to stock ownership. The bill is currently under consideration in Congress and will need to pass both the House and Senate before it can become law.