II 116th CONGRESS 1st Session S. 2589 IN THE SENATE OF THE UNITED STATES September 26, 2019 Mr. Isakson introduced the following bill; which was read twice and referred to the Committee on Finance A BILL To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations, and for other purposes.