To amend the Internal Revenue Code of 1986 to allow all employees of a firm to be counted as a single shareholder toward the shareholder limit of an S corporation.

This bill amends the Internal Revenue Code, with respect to the limit on the number of shareholders of an S corporation, to: (1) allow employees (and their estates) of the S corporation and any wholly owned business entities of the corporation to be treated as one shareholder if the corporation only has employee shareholders; (2) allow nonresident aliens to be shareholders if the nonresident alien is an employee, or the spouse of an employee, of such a corporation; and (3) establish tax withholding requirements for nonresident aliens who are permitted to be shareholders under this bill.