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

HR 2186 amends the tax code to clarify ownership rules for certain foreign-owned companies. It prevents U.S. shareholders from being treated as owning stock held by non-U.S. persons in foreign corporations (ending "downward attribution"). This directly affects "foreign controlled U.S. shareholders" - U.S. persons who would qualify as shareholders under modified ownership rules - requiring them to include specific foreign earnings in their gross income under new Section 951B. The changes apply to tax years ending after December 31, 2024.