1. 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.