毕马威：2025年“大而美法案”国际税收条款研究报告（英文版）

The Senate bill also adds new section 951B, which applies the CFC inclusion rules to “foreign controlled U.S. shareholders” (F-USSHs) of “foreign controlled CFCs” (F-CFCs). First proposed in connection with the restoration of section 958(b)(4) as part of the technical corrections package to the TCJA in 2019 and included in the House-passed BBBA in 2022, this provision defines F-USSHs and F-CFCs based on the existing definitions of U.S. shareholder and CFC, but with two important differences.