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To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.
Legislative Progress
Momentum (last 30 days)
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0 actions · 0 new cosponsors · 0 votes
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vs 10,940 other HR bills in the 119th — cohort avg 30d
No CRS summary is available for this bill yet. The source title, actions, sponsors, and text versions below come from Congress.gov.
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 (6)
2025 · fourth_quarter · Taxation/Internal Revenue Code
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
Issues related to corporate and international taxation. Issues related to OECD Pillar 1 and Pillar 2 negotiations and agreements on the taxation of global income. Issues related to tax code sections 11, 164(a), 951A, 250, 174, 41, and 958(b)(4).(H.R. 2186, S. 1605 - Section 6, H.R. 1 - Sections 70302, 70321, 70322, 70323, 70353.)
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2025 · third_quarter · Taxation/Internal Revenue Code
The One Big Beautiful Bill Act (PL 119-21 ), including proposed changes to taxes on certain partnerships and passive foreign investments, the Carried Interest Fairness Act (H.R. 1091/S. 445), the AIMM Act (H.R. 1347 /S. 559), the Small Business Investor Tax Parity Act (H.R. 652), the ALIGN Act H.R. 574/S. 187)legislation to provide a permanent extension of R&D expensing (H.R. 1990/S. 1639), and legislation related to the restoration of the imitation on downward attribution of stock ownership (H.R. 2186).
Client expense: $680,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2025 · third_quarter · Taxation/Internal Revenue Code
Rum cover over tax extender generally. HR 1378 and S 1986, To amend the Internal Revenue Code of 1986 to extend the temporary increase in limitation on the cover over of distilled spirits taxes to Puerto Rico and the Virgin Islands. S 1938, To amend the Internal Revenue Code of 1986 to modify the cover over of certain distilled spirits taxes. Excise taxes on alcohol generally. HR 2186, To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules. HR 1, One Big Beautiful Bill Act, concerning the rum cover over extension, downward attribution and duty drawback for alcohol.
Client expense: $120,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2025 · third_quarter · Taxation/Internal Revenue Code
PL# 115-97; Issues related to The Tax Cuts and Jobs Act. H.R.1; Issues related to the One Big Beautiful Bill Act; 70302, 70321, 70322, 70323, 70353. Issues related to OECD Pillar I and Pillar II rules. Issues related to corporate and international taxation. Issues related to tax code sections 11, 164(a), 951A, 250, 174, 41, and 958(b)(4). H.R. 2186; To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.
Client expense: $1,020,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE, Treasury, Dept of
2025 · third_quarter · Taxation/Internal Revenue Code
Issues related to corporate and international taxation. Issues related to OECD Pillar 1 and Pillar 2 negotiations and agreements on the taxation of global income. Issues related to tax code sections 11, 164(a), 951A, 250, 174, 41, and 958(b)(4).(H.R. 2186, S. 1605 - Section 6, H.R. 1 - Sections 70302, 70321, 70322, 70323, 70353.)
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2025 · second_quarter · Taxation/Internal Revenue Code
The One Big Beautiful Bill Act (PL 119-21), including proposed changes to taxes on certain partnerships and passive foreign investments, the Carried Interest Fairness Act (H.R. 1091/S. 445), the AIMM Act (H.R. 1347/S. 559), the Small Business Investor Tax Parity Act (H.R. 652), the ALIGN Act (H.R. 574/S. 187)legislation to provide a permanent extension of R&D expensing (H.R. 1990/S. 1639), and legislation related to the restoration of the limitation on downward attribution of stock ownership (H.R. 2186).
Client expense: $620,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2025 · second_quarter · Taxation/Internal Revenue Code
Rum cover over tax extender generally. HR 1378 and S 1986, To amend the Internal Revenue Code of 1986 to extend the temporary increase in limitation on the cover over of distilled spirits taxes to Puerto Rico and the Virgin Islands. S 1938, To amend the Internal Revenue Code of 1986 to modify the cover over of certain distilled spirits taxes. Excise taxes on alcohol generally. HR 2186, To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules. HR 1, One Big Beautiful Bill Act, concerning the rum cover over extension, downward attribution and duty drawback for alcohol.
Client expense: $120,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2025 · second_quarter · Taxation/Internal Revenue Code
Rum cover over tax extender generally. HR 1378 and S 1986, To amend the Internal Revenue Code of 1986 to extend the temporary increase in limitation on the cover over of distilled spirits taxes to Puerto Rico and the Virgin Islands. S 1938, To amend the Internal Revenue Code of 1986 to modify the cover over of certain distilled spirits taxes. Excise taxes on alcohol generally. HR 2186, To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules. HR 1, One Big Beautiful Bill Act, concerning the rum cover over extension, downward attribution and duty drawback for alcohol.
Client expense: $100,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2025 · second_quarter · Taxation/Internal Revenue Code
Tax reform. Issues related to OECD Pillar I and Pillar II rules. PL# 115-97; H.R.1; Issues related to The Tax Cuts and Jobs Act; Issues related to the One Big Beautiful Bill Act; Issues related to corporate and international taxation. H.R. 2186; To amend the Internal Revenue Code of 1986 to restore limitation on downward attribution of stock ownership in applying constructive ownership rules. Issues related to tax code sections 11, 951A, 250, 55, 56A, 59, 174, 41 and 958(b)(4).
Client expense: $1,300,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2025 · second_quarter · Taxation/Internal Revenue Code
Issues related to corporate and international taxation. Issues related to OECD Pillar 1 and Pillar 2 negotiations and agreements on the taxation of global income. Issues related to tax code sections 11, 164(a), 951A, 250, 174, 41, and 958(b)(4).(H.R. 2186, S. 1605 - Section 6, H.R. 1 - Sections 70302, 70321, 70322, 70323, 70353.)
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2025 · first_quarter · Taxation/Internal Revenue Code
Issues related to tax policy in the US-Taiwan Expedited Double Taxation Relief Act (H.R. 33) Issues related to the Base Erosion & Anti Abuse Tax and other International Tax Provisions in the Ta Cuts and Jobs Act (PL 115-97) Issues related to tax policy- HR 2186 - Restoring of limitation on downward attribution of stock ownership
Client expense: $190,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2025 · first_quarter · Taxation/Internal Revenue Code
Rum cover over tax extender generally. HR 1378, To amend the Internal Revenue Code of 1986 to extend the temporary increase in limitation on the cover over of distilled spirits taxes to Puerto Rico and the Virgin Islands. Excise taxes on alcohol generally. HR 2186, To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.
Client expense: $130,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2025 · first_quarter · Taxation/Internal Revenue Code
Federal tax issues affecting private equity firms, H.R. 1347, American Investment in Manufacturing and Main Street Act or the AIMM Act, and H.R. 2186, Bill to amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.
Client expense: Not reported · Firm income: $80,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2025 · first_quarter · Taxation/Internal Revenue Code
Issues related to corporate and international taxation. Issues related to OECD Pillar 1 and Pillar 2 negotiations and agreements on the taxation of global income. Issues related to tax code sections 11, 164(a), 951A, 250, 174, 41, and 958(b)(4).(H.R. 2186)
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2025 · first_quarter · Taxation/Internal Revenue Code
Issues related to the OECD Pillar 1 and Pillar 2 model rules. PL# 115-97; Issues related to The Tax Cuts and Jobs Act; issues related to corporate and international taxation. H.R. 2186; To amend the Internal Revenue Code of 1986 to restore limitation on downward attribution of stock ownership in applying constructive ownership rules. Issues related to tax code sections 11, 951A, 250, 55, 56A, 59, 174, 41 and 958(b)(4).
Client expense: $1,160,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of