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

# Summary of HR 2186 **What the Bill Would Do:** This bill would change how the Internal Revenue Service (IRS) calculates stock ownership for tax purposes. Specifically, it would restore a previous limitation on "downward attribution" of stock ownership—a technical tax rule that determines when a person is considered to own stock that's technically owned by a family member or related entity. The bill would reinstate rules that limit how far down the ownership chain the IRS can attribute stock ownership, potentially allowing certain business owners to structure their holdings in ways that reduce tax liability. **Who It Affects and Key Provisions:** The bill would primarily affect business owners and investors who structure their holdings through family members, trusts, or other related entities. By restoring limits on downward attribution, it could allow these taxpayers to claim lower ownership stakes in certain businesses for tax purposes.

The specific mechanics of the change involve amending the Internal Revenue Code's constructive ownership rules, which are complex tax regulations used to prevent tax avoidance strategies. **Current Status:** As of now, HR 2186 remains in committee and has not advanced further in the legislative process. The bill was introduced by Rep. Ron Estes (R-KS) in the 119th Congress. No action has been taken to bring it to a vote.