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139 STAT. 209 PUBLIC LAW 119–21—JULY 4, 2025 (A) such change shall be treated as initiated by such corporation, (B) such change shall be treated as having been made with the consent of the Secretary, and (C) the Secretary shall issue regulations or other guid- ance for allocating foreign taxes that are paid or accrued in such first taxable year and the succeeding taxable year among such taxable years in the manner the Secretary determines appropriate to carry out the purposes of this section. (2) SECRETARY.—For purposes of this subsection, the term ‘‘Secretary’’ means the Secretary of the Treasury or the Sec- retary’s delegate. SEC. 70353. RESTORATION OF LIMITATION ON DOWNWARD ATTRIBU- TION OF STOCK OWNERSHIP IN APPLYING CONSTRUC- TIVE OWNERSHIP RULES. (a) IN GENERAL.—Section 958(b) is amended— (1) by inserting after paragraph (3) the following: ‘‘(4) Subparagraphs (A), (B), and (C) of section 318(a)(3) shall not be applied so as to consider a United States person as owning stock which is owned by a person who is not a United States person.’’, and (2) by striking ‘‘Paragraph (1)’’ in the last sentence and inserting ‘‘Paragraphs (1) and (4)’’. (b) FOREIGN CONTROLLED UNITED STATES SHAREHOLDERS.— Subpart F of part III of subchapter N of chapter 1 is amended by inserting after section 951A the following new section: ‘‘SEC. 951B. AMOUNTS INCLUDED IN GROSS INCOME OF FOREIGN CON- TROLLED UNITED STATES SHAREHOLDERS. ‘‘(a) IN GENERAL.—In the case of any foreign controlled United States shareholder of a foreign controlled foreign corporation— ‘‘(1) this subpart (other than sections 951A, 951(b), and 957) shall be applied with respect to such shareholder (sepa- rately from, and in addition to, the application of this subpart without regard to this section)— ‘‘(A) by substituting ‘foreign controlled United States shareholder’ for ‘United States shareholder’ each place it appears therein, and ‘‘(B) by substituting ‘foreign controlled foreign corpora- tion’ for ‘controlled foreign corporation’ each place it appears therein, and ‘‘(2) section 951A (and such other provisions of this subpart as provided by the Secretary) shall be applied with respect to such shareholder— ‘‘(A) by treating each reference to ‘United States share- holder’ in such section as including a reference to such shareholder, and ‘‘(B) by treating each reference to ‘controlled foreign corporation’ in such section as including a reference to such foreign controlled foreign corporation. ‘‘(b) FOREIGN CONTROLLED UNITED STATES SHAREHOLDER.—For purposes of this section, the term ‘foreign controlled United States shareholder’ means, with respect to any foreign corporation, any United States person which would be a United States shareholder with respect to such foreign corporation if— Applicability. Definitions. 26 USC 951B. Definition. Regulations. Guidance. Allocations.