119th Congress · introduced in the House · Mar 18, 2025
To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.
Official title from Congress.gov
Latest action (Mar 18, 2025): Referred to the House Committee on Ways and Means.
View on Congress.govPolicy area: Taxation
No official summary has been published for this bill.
Includes amendment, cloture, and procedural votes. Each is labeled with its exact question; only a passage question is a vote to pass the bill.
No recorded roll calls on this bill in coverage.
Referred to the House Committee on Ways and Means.
Introduced in House
Introduced in House
Actions from Congress.gov, newest first.
LD-2 reports whose issue descriptions explicitly cite this bill (bill type and number validated against Congress.gov records). A citation does not establish the client's position or any contact with a member.
Loading lobbying reportsCoverage: reports for 2025 onward, posted Jan 1, 2025 through Oct 23, 2026.
14 citations.
THE COCA COLA COMPANY · lobbying firm or registrant: THE WASHINGTON TAX & PUBLIC POLICY GROUP
2025 Q4 report (Oct 1, 2025 – Dec 31, 2025) · posted Jan 20, 2026 · issue area: Taxation/Internal Revenue Code
$60,000
Paid to lobbying firm
…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.)
Congress inferred from the report year; bill number matches Congress.gov records and the bill predates the report; no title was cited with it. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
AMERICAN INVESTMENT COUNCIL F/K/A PEGCC · lobbying firm or registrant: AMERICAN INVESTMENT COUNCIL F/K/A PEGCC
2025 Q3 report (Jul 1, 2025 – Sep 30, 2025) · posted Oct 20, 2025 · issue area: Taxation/Internal Revenue Code
$680,000
Spent on own lobbying
…anent 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).
Congress inferred from the report year; bill number matches Congress.gov records and the bill predates the report; no title was cited with it. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
BACARDI NORTH AMERICA (FORMERLY BACARDI USA INC) · lobbying firm or registrant: BACARDI NORTH AMERICA (FORMERLY BACARDI USA, INC)
2025 Q3 report (Jul 1, 2025 – Sep 30, 2025) · posted Oct 17, 2025 · issue area: Taxation/Internal Revenue Code
$120,000
Spent on own lobbying
…gin 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…
Congress inferred from the report year; bill number and the title cited with it match Congress.gov records, and the bill predates the report. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
COCA-COLA COMPANY · lobbying firm or registrant: THE COCA-COLA COMPANY
2025 Q3 report (Jul 1, 2025 – Sep 30, 2025) · posted Oct 17, 2025 · issue area: Taxation/Internal Revenue Code
$1,020,000
Spent on own lobbying
…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.
Congress inferred from the report year; bill number matches Congress.gov records and the bill predates the report; no title was cited with it. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
THE COCA COLA COMPANY · lobbying firm or registrant: THE WASHINGTON TAX & PUBLIC POLICY GROUP
2025 Q3 report (Jul 1, 2025 – Sep 30, 2025) · posted Oct 16, 2025 · issue area: Taxation/Internal Revenue Code
$60,000
Paid to lobbying firm
…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.)
Congress inferred from the report year; bill number matches Congress.gov records and the bill predates the report; no title was cited with it. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
AMERICAN INVESTMENT COUNCIL F/K/A PEGCC · lobbying firm or registrant: AMERICAN INVESTMENT COUNCIL F/K/A PEGCC
2025 Q2 report (Apr 1, 2025 – Jun 30, 2025) · posted Jul 21, 2025 · issue area: Taxation/Internal Revenue Code
$620,000
Spent on own lobbying
…manent 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).
Congress inferred from the report year; bill number matches Congress.gov records and the bill predates the report; no title was cited with it. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
BACARDI NORTH AMERICA (FORMERLY BACARDI USA INC) · lobbying firm or registrant: BACARDI NORTH AMERICA (FORMERLY BACARDI USA, INC)
2025 Q2 report (Apr 1, 2025 – Jun 30, 2025) · amended · posted Jul 21, 2025 · issue area: Taxation/Internal Revenue Code
$120,000
Spent on own lobbying
…gin 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…
Congress inferred from the report year; bill number and the title cited with it match Congress.gov records, and the bill predates the report. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
COCA-COLA COMPANY · lobbying firm or registrant: THE COCA-COLA COMPANY
2025 Q2 report (Apr 1, 2025 – Jun 30, 2025) · posted Jul 18, 2025 · issue area: Taxation/Internal Revenue Code
$1,300,000
Spent on own lobbying
…; 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 r…
Congress inferred from the report year; bill number matches Congress.gov records and the bill predates the report; no title was cited with it. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
THE COCA COLA COMPANY · lobbying firm or registrant: THE WASHINGTON TAX & PUBLIC POLICY GROUP
2025 Q2 report (Apr 1, 2025 – Jun 30, 2025) · posted Jul 18, 2025 · issue area: Taxation/Internal Revenue Code
$60,000
Paid to lobbying firm
…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.)
Congress inferred from the report year; bill number matches Congress.gov records and the bill predates the report; no title was cited with it. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
GARMIN INTERNATIONAL, INC. · lobbying firm or registrant: GARMIN INTERNATIONAL, INC.
2025 Q1 report (Jan 1, 2025 – Mar 31, 2025) · posted Apr 22, 2025 · issue area: Taxation/Internal Revenue Code
$190,000
Spent on own lobbying
…ssues 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
Congress inferred from the report year; bill number matches Congress.gov records and the bill predates the report; no title was cited with it. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
BACARDI NORTH AMERICA (FORMERLY BACARDI USA INC) · lobbying firm or registrant: BACARDI NORTH AMERICA (FORMERLY BACARDI USA, INC)
2025 Q1 report (Jan 1, 2025 – Mar 31, 2025) · posted Apr 21, 2025 · issue area: Taxation/Internal Revenue Code
$130,000
Spent on own lobbying
…end 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.
Congress inferred from the report year; bill number and the title cited with it match Congress.gov records, and the bill predates the report. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
AMERICAN INVESTMENT COUNCIL · lobbying firm or registrant: CAPITOL TAX PARTNERS, LLP
2025 Q1 report (Jan 1, 2025 – Mar 31, 2025) · posted Apr 21, 2025 · issue area: Taxation/Internal Revenue Code
$80,000
Paid to lobbying firm
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.
Congress inferred from the report year; bill number matches Congress.gov records and the bill predates the report; no title was cited with it. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
THE COCA COLA COMPANY · lobbying firm or registrant: THE WASHINGTON TAX & PUBLIC POLICY GROUP
2025 Q1 report (Jan 1, 2025 – Mar 31, 2025) · posted Apr 21, 2025 · issue area: Taxation/Internal Revenue Code
$60,000
Paid to lobbying firm
…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)
Congress inferred from the report year; bill number matches Congress.gov records and the bill predates the report; no title was cited with it. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
COCA-COLA COMPANY · lobbying firm or registrant: THE COCA-COLA COMPANY
2025 Q1 report (Jan 1, 2025 – Mar 31, 2025) · posted Apr 18, 2025 · issue area: Taxation/Internal Revenue Code
$1,160,000
Spent on own lobbying
…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 r…
Congress inferred from the report year; bill number matches Congress.gov records and the bill predates the report; no title was cited with it. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing