; and (2) if credit or refund of such portion is made after the date which is 45 days after the date of the enactment of this Act, no interest shall be allowed or paid under section 6611 of such Code with respect to such portion for any period before the date of the enactment of this Act. (c) Effective date The amendment made by subsection (a) shall take effect as if included in section 14103 of Public Law 115–97 . 2209. Restoration of limitation on downward attribution of stock ownership in applying constructive ownership rules (a) In general Section 958(b) of the Internal Revenue Code of 1986 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 of such Code is amended by inserting after section 951A the following new section: 951B. Amounts included in gross income of foreign controlled 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), 957, and 965) shall be applied with respect to such shareholder (separately 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 corporation for controlled foreign corporation each place it appears therein, and (2) sections 951A and 965 shall be applied with respect to such shareholder — (A) by treating each reference to United States shareholder in such sections as including a reference to such shareholder, and (B) by