IRC Section 318
26 U.S. Code § 318 - Constructive ownership of stock
26 U.S. Code § 318 - Constructive ownership of stock ... his children, grandchildren, and parents. ... For purposes of subparagraph (A)(ii), a legally adopted child ...
IRC Section 318: Attribution Rules Chart & Full Code Text - Tax Notes
Under IRC section 318(a)(1), an individual is considered to own the stock owned, directly or indirectly, by or for his spouse (other than a spouse who is ...
Page 971 TITLE 26—INTERNAL REVENUE CODE § 318 - GovInfo
31, 1964], except that, for purposes of sections 302 and 304 of the Internal Revenue Code of 1986. [formerly I.R.C. 1954], such amendments shall not apply.
318, Constructive Ownership of Stock - Income Taxes - IRC
Stock owned, directly or indirectly, by or for a partnership or estate shall be considered as owned proportionately by its partners or beneficiaries.
26 CFR § 1.318-1 - Constructive ownership of stock; introduction.
(a) For the purposes of certain provisions of chapter 1 of the Code, section 318(a) provides that stock owned by a taxpayer includes stock constructively owned ...
201533006.pdf - Internal Revenue Service
of the Code, the stock owned by a taxpayer includes stock constructively owned by such taxpayer (the "attribution rules"). Section 318(a)(2 ...
318, Constructive Ownership of Stock - Income Taxes - Explanations
318IRC §318 provides rules for determining the circumstances in which stock ownership is attributed from one individual or entity to another.
Constructive ownership of stock, 26 U.S.C. § 318 - Casetext
318(a)(2)(C), as modified by IRC Sec. 958(b)(2 ... Ownership determinations for CFCs have always included the IRC Section 318 constructive ownership rules.
26 U.S.C. § 318 - U.S. Code Title 26. Internal Revenue Code § 318
(A) From partnerships and estates.--Stock owned, directly or indirectly, by or for a partnership or estate shall be considered as owned proportionately by its ...
IRC 318: Constructive Ownership of Stock & Regulations
IRC 318 & Constructive Ownership of Stock: When a person owns an asset – such as stock – and they paid for the stock and/or acquired it under their own name, ...
The Application of the Indirect and Constructive Ownership Rules ...
See IRC Section 318(a)(5)(B). 2. Entity to Beneficiary Attribution. Stock owned by or for a partnership or estate is considered as owned by ...
If You and Your Family Members Own Stock in the Same ...
Section 318(a) of the tax code sets forth the family attribution rules for stock ownership in a corporation. For family members who all own ...
IRC Section 318 Archives - Sherayzen Law Office
§318(a)(1)(A) describes the §318 family attribution rule . It states that an individual is a constructive owner of shares owned (directly and indirectly) by his ...
Page 1101 TITLE 26—INTERNAL REVENUE CODE § 318 - GovInfo
31, 1964], except that, for purposes of sections 302 and 304 of the Internal. Revenue Code of 1986 [formerly I.R.C. 1954], such amendments shall not apply ...
Sec. 1.318-4 Constructive ownership as actual ownership; exceptions.
Section 318(a)(5)(A) provides that, except as provided in section 318(a)(5 ... Internal Revenue Code of 1986Browse IRC 1986; Browse Regulations. ×. Add to ...
§318 Downstream Trust Attribution | Foreign Trust Tax Lawyer ...
The Internal Revenue Code (“IRC”) §318 contains complex ... IRC Section 318 attorney. Share this entry. Share on Facebook · Share on ...
Attribution of Ownership FAQ - DWC | The 401(k) Experts
Internal Revenue Code section 318. Used to determine who is a highly compensated employee, key employee or a disqualified person in an Employee Stock ...
Attribution of Stock Ownership from Stock Options under the Internal ...
... I.R.C. §§ 318, 544 & 1563. See also text and notes at notes 130-41 infra ... make section 318's option attribution rules"9 applicable in deter- mining ...
IRC 958 Rules for Determining Stock Ownership - IRS
▫ IRC 318(a)(3)(C); and IRC 6038(a). ▫ IRC 6038(a)(4). Go to ... Section 958(a) Exception for Purposes of IRC 951A GILTI Inclusions.
How to Attribute Family Ownership When 401(k) Plan Testing
The IRC section 1563 attribution rules apply to controlled group determinations while IRC section 318 apply for other testing purposes. These ...