A bill to amend the Internal Revenue Code of 1986 to prevent avoidance of tax by certain foreign-owned corporations and to impose a tax on dispositions of stock in domestic corporations by 10-percent foreign shareholders.

Title I: Treatment of Certain Foreign-Owned Corporations - Applies the Revenue Reconciliation Act of 1989 amendments regarding information reporting requirements by certain foreign-owned corporations to taxable years beginning on or before July 10, 1989.

Amends the Internal Revenue Code to establish information reporting requirements for foreign corporations engaged in business within the United States.

Extends the statute of limitations for the assessment of any foreign-related deficiency by an additional period of not more than three years.

Title II: Tax on Disposition of Stock in Domestic Corporations by 10-Percent Foreign Shareholders - Provides that if any nonresident alien corporation is a ten-percent shareholder in a domestic corporation, any gain or loss from the disposition of any stock in such domestic corporation shall be taken into account as if the taxpayer were effectively connected with U.S. trade or business.

Requires a withholding agent to withhold ten percent of the tax realized on certain stock dispositions by such ten-percent shareholders.