HR5751-118

Introduced

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

118th Congress Introduced Sep 27, 2023

Analysis under review: This bill has generated analysis that may be too generic or incomplete. Clause-level evidence remains available below.

Summary

What This Bill Does

This bill, To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules., changes federal law or congressional policy affecting environmental regulators and natural-resource users. The main policy domain is Environment, Foreign Policy, Government Operations.

Who Benefits and How

environmental regulators and natural-resource users may benefit from new authority, funding, eligibility, regulatory clarity, or reduced risk created by the bill.

Who Bears the Burden and How

federal implementing agencies, environmental regulators and natural-resource users may take on implementation duties, reporting obligations, compliance costs, or oversight responsibilities.

Key Provisions

  • Section HD8B39CD143844C6296B5C86A648EE439: 1. Restoration of limitation on downward attribution of stock ownership in applying constructive ownership rules Section 958(b) of the Internal Revenue Code of...
  • Section H4C4C5E0428894F328CA3DDDFF1F77E96: 951B. Amounts included in gross income of foreign controlled United States shareholders In the case of any foreign controlled United States shareholder of a...

Evidence Chain:

This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.

At a Glance

What This Bill Does

This bill, To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules., changes federal law or congressional policy affecting environmental regulators and natural-resource users.

Key Policy Areas

Environment, Foreign Policy, Government Operations

Primary Purpose

This bill, To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules., changes federal law or congressional policy affecting environmental regulators and natural-resource users.

Policy Domains

Environment Foreign Policy Government Operations

Whole bill

Identified Gains
  • environmental regulators and natural-resource users
Model: codex-gpt-5 | Version: bill_summary_v2 | Source: ih
environmental regulators and natural-resource users: ,
Identified Costs
  • federal implementing agencies
  • environmental regulators and natural-resource users
Model: codex-gpt-5 | Version: bill_summary_v2 | Source: ih
federal implementing agencies: ,
environmental regulators and natural-resource users: ,

Legislative Progress

Introduced
Introduced Committee Passed
Sep 27, 2023

Mr. Ferguson (for himself, Ms. Moore of Wisconsin, Mr. Estes, …

Impact analysis is available but no clear stakeholder effects identified. View clause-level analysis →

Bill Structure & Actor Mappings

Who is "The Secretary" in each section?

Domains
Environment Foreign Policy Government Operations
Actor Mappings
"the_secretary"
→ The Secretary identified in the operative section

We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.

Learn more about our methodology