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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.
Legislative Progress
Momentum (last 30 days)
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0 actions · 0 new cosponsors · 0 votes
Speed vs cohort
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vs 9,062 other HR bills in the 116th — cohort avg 39d
This bill amends the Internal Revenue Code to limit the scope of downward attribution rules to 50% of stock ownership in applying constructive ownership rules to controlled foreign corporations.
These links require the bill number to appear in the filing's source-reported specific issue text. Client expenses and lobbying-firm income are separate disclosure fields.
Filing registrants (8)
Referred to the House Committee on Ways and Means.
Introduced in House
Congress.gov source codes: 1000, Intro-H
Bills with similar content found using semantic analysis.
Sources: Congress.gov
2021 · fourth_quarter · Energy/Nuclear
Met with Representatives and legislative staff to discuss support for the Department of Energy's Geothermal Technologies program as a platform for a demonstration project. Expressed support for full funding the DoE EERE Geothermal Technologies program as authorized in the Energy Act of 2020 in the FY22 Energy & Water Appropriations bill. (HR 4509, S 2605) Asked Representatives and legislative staff to support the DOE Science for the Future Act (HR 3593).
Client expense: $90,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE
2021 · third_quarter · Energy/Nuclear
Met with Representatives and legislative staff to discuss support for the Department of Energy's Geothermal Technologies program as a platform for a demonstration project. Expressed support for full funding the DoE EERE Geothermal Technologies program as authorized in the Energy Act of 2020 in the FY22 Energy & Water Approprations bill. (HR 4509, S 2605) Asked Representatives and legislative staff to support the DOE Science for the Future Act (HR 3593).
Client expense: $120,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE
2020 · fourth_quarter · Taxation/Internal Revenue Code
HR 1175/S 362 Craft Beverage Modernization and Tax Reform Act of 2019; provisions related to craft beverage tax relief HR 4509/S 2589 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; all provisions of the bill
Client expense: $2,520,000 · Firm income: Not reported
Government targets: Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Office of Management & Budget (OMB), SENATE, White House Office
2020 · fourth_quarter · Taxation/Internal Revenue Code
HR 1175/S 362 Craft Beverage Modernization and Tax Reform Act of 2019; provisions related to craft beverage tax relief HR 4509/S 2589 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; all provisions of the bill
Client expense: $2,510,000 · Firm income: Not reported
Government targets: Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Office of Management & Budget (OMB), SENATE, White House Office
2020 · fourth_quarter · Taxation/Internal Revenue Code
Corporate tax issues. Issues related to tax extenders legislation. H. R. 4509, 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.
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2020 · fourth_quarter · Taxation/Internal Revenue Code
US policy regarding foreign implementation of digital taxes and 301 retaliatory tariffs. H.R. 5674 Mobile Workforce State Income Tax Simplification Act of 2020. Issues of employees working across State/international borders, especially in time of COVID lockdowns. H.R.4796/ S. 604 - Mobile Workforce State Income Tax Simplification Act of 2019. Issues of employees working across State/international borders, especially in time of COVID lockdowns. S.4318 American Workers, Families, and Employers Assistance Act. Issues of employees working across State/international borders, especially in time of COVID lockdowns. S.2589 & H.R.4509 - A bill 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. Issues related to corporate and international tax and issues related to OECD negotiations on the taxation of global income.
Client expense: $1,150,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Natl Economic Council (NEC), SENATE, Treasury, Dept of, White House Office
2020 · fourth_quarter · Consumer Issues/Safety/Products
Monitored issues related to Data Privacy, Spectrum, Tax Policy, Aviation, and Anti-Trust. Implementation of Tax Cuts and Jobs Act (P.L.115-97). S.2589/H.R.4509, A bill 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.
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2020 · fourth_quarter · Taxation/Internal Revenue Code
General tax legislative and regulatory issues; H.R. 4509; and S. 2589.
Client expense: Not reported · Firm income: $20,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2020 · third_quarter · Taxation/Internal Revenue Code
HR 1175/S 362 Craft Beverage Modernization and Tax Reform Act of 2019; provisions related to craft beverage tax relief HR 4509/S 2589 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; all provisions of the bill
Client expense: $3,090,000 · Firm income: Not reported
Government targets: Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, SENATE, White House Office
2020 · third_quarter · Consumer Issues/Safety/Products
Monitored issues related to Data Privacy, Spectrum, Tax Policy, Aviation, and Anti-Trust. Implementation of Tax Cuts and Jobs Act (P.L.115-97). S.2589/H.R.4509, A bill 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.
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2020 · third_quarter · Taxation/Internal Revenue Code
Corporate tax issues. Issues related to tax extenders legislation. H. R. 4509, 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.
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2020 · third_quarter · Taxation/Internal Revenue Code
US policy regarding foreign implementation of digital taxes and 301 retaliatory tariffs. H.R. 5674 Mobile Workforce State Income Tax Simplification Act of 2020. Issues of employees working across State/international borders, especially in time of COVID lockdowns. H.R.4796/ S. 604 - Mobile Workforce State Income Tax Simplification Act of 2019. Issues of employees working across State/international borders, especially in time of COVID lockdowns. S.4318 American Workers, Families, and Employers Assistance Act. Issues of employees working across State/international borders, especially in time of COVID lockdowns. S.2589 & H.R.4509 - A bill 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. Issues related to corporate and international tax and issues related to OECD negotiations on the taxation of global income.
Client expense: $1,540,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2020 · third_quarter · Taxation/Internal Revenue Code
General tax legislative and regulatory issues; H.R. 4509; and S. 2589.
Client expense: Not reported · Firm income: $10,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2020 · second_quarter · Consumer Issues/Safety/Products
Monitored issues related to Data Privacy, Spectrum, Tax Policy, Aviation, and Anti-Trust. Implementation of Tax Cuts and Jobs Act (P.L.115-97). S.2589/H.R.4509, A bill 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.
Client expense: Not reported · Firm income: $20,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2020 · second_quarter · Taxation/Internal Revenue Code
HR 1175/S 362 Craft Beverage Modernization and Tax Reform Act of 2019; provisions related to craft beverage tax relief HR 4509/S 2589 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; all provisions of the bill
Client expense: $2,300,000 · Firm income: Not reported
Government targets: Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, SENATE, White House Office
2020 · second_quarter · Taxation/Internal Revenue Code
Corporate tax issues. Issues related to tax extenders legislation. H. R. 4509, 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.
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2020 · second_quarter · Taxation/Internal Revenue Code
General tax legislative and regulatory issues; H.R. 4509; S. 2589; and S. 3548, the CARES Act.
Client expense: Not reported · Firm income: $10,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2020 · first_quarter · Taxation/Internal Revenue Code
HR 748 CARES Act; tax provisions affecting corporations and small businesses; and provisions related to downward attribution rules. HR 1175 Craft Beverage Modernization and Tax Reform Act of 2019; provisions related to craft beverage tax relief HR 6201 Families First Coronavirus Response Act; tax provisions affecting corporations and small businesses; and provisions related to downward attribution rules. HR 4509/S 2589To 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; all provisions of the bill
Client expense: $2,660,000 · Firm income: Not reported
2020 · first_quarter · Taxation/Internal Revenue Code
Corporate tax issues. Issues related to tax extenders legislation. H. R. 4509, 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.
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2020 · first_quarter · Taxation/Internal Revenue Code
HR 4509/S 2589 A bill 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 Downward Attribution and phantom controlled foreign corporations. Implementation of PL 115-97, Tax Cuts & Jobs Act, follow-up issues related to GILTI provisions US policy regarding foreign implementation of digital taxes S 803/HR 1869 Restoring Investment in Improvements Act
Client expense: $2,260,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2020 · first_quarter · Taxation/Internal Revenue Code
General tax legislative and regulatory issues; H.R. 4509; S. 2589; and S. 3548, the CARES Act.
Client expense: Not reported · Firm income: $20,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2020 · first_quarter · Consumer Issues/Safety/Products
Monitored issues related to Data Privacy, Spectrum, Tax Policy, Aviation, and Anti-Trust. Implementation of Tax Cuts and Jobs Act (P.L.115-97). S.2589/H.R.4509, A bill 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.
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2020 · first_quarter · Taxation/Internal Revenue Code
Issues related to corporate and international tax including issues related to IRC sections 904(d), 951A, 250, 59A, 163(j), 954(c)(6), 958(b)(4), 174, 199 and 7652. (H.R. 4509, S .2589, and H.R. 748). Issues related to Puerto Rico, tax treaties and issues related to OECD negotiations on the taxation of global income.
Client expense: Not reported · Firm income: $30,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2019 · fourth_quarter · Taxation/Internal Revenue Code
Corporate tax issues. Issues related to tax extenders legislation. H. R. 4509, 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.
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2019 · fourth_quarter · Taxation/Internal Revenue Code
Tax issues regarding financial services industry including issues regarding Tax Cuts & Jobs Act and H.R. 4509 & S. 2589, Bill 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.
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2019 · fourth_quarter · Taxation/Internal Revenue Code
HR 1175 Craft Beverage Modernization and Tax Reform Act of 2019; provisions related to craft beverage tax relief HR 4509/S 2589 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; all provisions of the bill Discussions concerning section 958(b)(4) of the Internal Revenue Code and reforms regarding constructive ownership and foreign attribution
Client expense: $3,030,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, White House Office
2019 · fourth_quarter · Taxation/Internal Revenue Code
General tax legislative and regulatory issues; H.R. 4509.
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2019 · fourth_quarter · Consumer Issues/Safety/Products
Monitored issues related to Data Privacy, Spectrum, Tax Policy, Aviation, and Anti-Trust. Implementation of Tax Cuts and Jobs Act (P.L.115-97). S.2589/H.R.4509, A bill 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.
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2019 · fourth_quarter · Taxation/Internal Revenue Code
Tax Technical and Clerical Corrections Act Discussion Draft: Implementation of PL115-97, Tax Cuts & Jobs Act; follow-up issues related to tax reform and implementation on stock attribution /phantom control Implementation of PL 115-97, Tax Cuts & Jobs Act, follow-up issues related to GILTI provisions S. 926/H.R. 1961/KOMBUCHA (Keeping Our Manufacturers from Being Unfairly taxed while Championing Health Act) H.R. 1175/S. 362 Craft Beverage Modernization and Tax Reform Act of 2019 Tax Treaties: Support of Senate passage of tax treaties with Spain, Hungary, Chile, Poland, Switzerland, Japan, Luxembourg H.R. 4509/S. 2589 A bill 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
Client expense: $1,350,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Environmental Protection Agency (EPA), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, Treasury, Dept of, U.S. Customs & Border Protection, U.S. Immigration & Customs Enforcement (ICE), U.S. Trade Representative (USTR)
2019 · fourth_quarter · Taxation/Internal Revenue Code
Issues related to corporate and international tax including issues related to IRC sections 904(d), 951A, 250, 59A, 163(j), 954(c)(6), 958(b)(4), 174, 199 and 7652. (HR 4509 and S 2589). Issues related to Puerto Rico, tax treaties and issues related to OECD negotiations on the taxation of global income. The Further Consolidated Appropriations Act, 2020, HR 1865.
Client expense: Not reported · Firm income: $30,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2019 · third_quarter · Taxation/Internal Revenue Code
HR 4509/S 2589To 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; all provisions of the bill Discussions concerning section 958(b)(4) of the Internal Revenue Code and reforms regarding constructive ownership and foreign attribution
Client expense: $2,430,000 · Firm income: Not reported
Government targets: Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, White House Office
2019 · third_quarter · Taxation/Internal Revenue Code
Tax Technical and Clerical Corrections Act Discussion Draft: Implementation of PL115-97, Tax Cuts & Jobs Act; follow-up issues related to tax reform and implementation on stock attribution /phantom control Implementation of PL 115-97, Tax Cuts & Jobs Act, follow-up issues related to GILTI provisions S. 926/H.R. 1961/KOMBUCHA (Keeping Our Manufacturers from Being Unfairly taxed while Championing Health Act) H.R. 1175/S. 362 Craft Beverage Modernization and Tax Reform Act of 2019 Tax Treaties: Support of Senate passage of tax treaties with Spain, Hungary, Chile, Poland, Switzerland, Japan, Luxembourg H.R. 4509/S. 2589 A bill 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
Client expense: $1,740,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Environmental Protection Agency (EPA), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Agency for International Development (USAID), U.S. Customs & Border Protection, U.S. Immigration & Customs Enforcement (ICE), U.S. Trade Representative (USTR), White House Office
2019 · third_quarter · Taxation/Internal Revenue Code
Issues related to corporate and international tax including issues related to IRC sections 904(d), 951A, 250, 59A, 163(j), 954(c)(6), 958(b)(4), 174, 199 and 7652. (HR 4509 and S 2589). Issues related to Puerto Rico, tax treaties and issues related to OECD negotiations on the taxation of global income.
Client expense: Not reported · Firm income: $30,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
| Democratic |
| WI |
| Lucy McBath | Democratic | GA |
| Ron Estes | Republican | KS |
| Stephanie N. Murphy | Democratic | FL |
Government targets: Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, SENATE