L. 88–554, § 4(a), struck out sidewise attribution by providing that when stock is attributed to a partnership, estate, trust, or corporation from a partner, shareholder, or beneficiary, this stock is not to be attributed again to another partner, beneficiary, or shareholder. However, after the TCJA repealed Section 958(b)(4), the floodgates opened. Foreign corporation stock owned by a foreign person became attributable to a US person if the US person was also a US shareholder in the CFC. A US shareholder is a person who directly, indirectly, or through attribution, owns at least 10% in a foreign corporation.