A bill to amend the provisions of the Internal Revenue Code of 1954 relating to controlled foreign corporations to make the constructive ownership rules inapplicable in determining deemed distributions to individuals with small individual and family interests in such corporations.

Amends the Internal Revenue Code to provide that for purposes of determining whether amounts are includible in the gross income of a U.S. shareholder of a controlled foreign corporation, individuals owning less than five percent and families owning less than 15 percent of all classes of stock entitled to vote shall not be treated as U.S. shareholders.