FAQs on Sec. 958(b)(4) and Sec. 951B

H.R. 1, P.L. 119-21, the law known as the One Big Beautiful Bill Act (OBBBA), reinstates subsection (b)(4) involving constructive ownership under Sec. 958, Rules for determining stock ownership and streamlines U.S. shareholder reporting requirements, which reduces Form 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations, filings and simplifies Subpart F/Global Intangible Low-Taxed Income (GILTI ) exposure. Additionally, a newly created Sec. 951B, Amounts included in gross income of foreign controlled United States shareholders, creates a