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

Cost and committee reports

Official records Congress.gov attaches to H.R. 2186.

• Constitutional authority statementThe sponsor’s statement of where the Constitution gives Congress the power to pass this bill. Statement by Mr. ESTES, as printed in the Congressional Record (Vol. 171, No. 50, March 18, 2025, Page H1172):
  Article 1, Section 8, Clause 1: The Congress shall have Power To lay and collect Taxes, Duties, Imposts and Excises, to pay the Debts and provide for the common Defence and general Welfare of the United States; but all Duties, Imposts and Excises shall be uniform throughout the United States;
  Source: Congress.gov, Congressional Record March 18, 2025 ↗

  Evidence

  Field in the Congress.gov record

  constitutionalAuthorityStatementText

  Statement length

  293 characters

  Congress.gov bill record

  H.R. 2186, 119th Congress

  Congress.gov API record

  https://api.congress.gov/v3/bill/119/hr/2186

  Record last updated by Congress.gov

  December 30, 2025

  PORKER copy retrieved

  September 13, 2026

  Stored copy, SHA-256 of the file

  b229a019e8576e796339c34a8eecc7a53918e295021d3e29a41104b300688f21

  PORKER shows the statement exactly as printed, with the page markup removed. It is the sponsor’s claim; it is not a legal finding.

Congress.gov’s record for this bill does not list a CBO cost estimate or a committee report (as of December 30, 2025). Not every bill gets one.

From the Congress.gov bill record for H.R. 2186, last updated December 30, 2025. PORKER’s copy was retrieved September 13, 2026 and is refreshed nightly. Open “Evidence” on any line for the record, field and file fingerprint.