Irc 958 rules for determining stock ownership
WebINTERNAL REVENUE CODE § 958. Rules for determining stock ownership., 26 USCS § 958. ... (other than section 960 [26 USCS § 960]), stock owned means— (A) stock owned … Web26 U.S. Code § 958 - Rules for determining stock ownership U.S. Code Notes prev next (a) Direct and indirect ownership (1) General rule For purposes of this subpart (other than section 960 ), stock owned means— (A) stock owned directly, and (B) stock owned with …
Irc 958 rules for determining stock ownership
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WebSection 958 - Rules for determining stock ownership (a) Direct and indirect ownership (1) General rule. For purposes of this subpart (other than section 960), stock owned means … WebRules for determining stock ownership(a) Direct and indirect ownership(1) General rule For purposes of this subpart (other than section 960(a)(1)), stock owned means— (A) stock owned directly, and (B) stock owned with the application of paragraph (2). (2) Stock ownership through foreign entities
Web§958. Rules for determining stock ownership (a) Direct and indirect ownership (1) General rule. For purposes of this subpart (other than section 960(a)(1)), stock owned means— … WebSec. 958. Rules For Determining Stock Ownership Sec. 959. Exclusion From Gross Income Of Previously Taxed Earnings And Profits Sec. 960. Deemed Paid Credit For Subpart F Inclusions (post-2024) Sec. 961. Adjustments To Basis Of Stock In Controlled Foreign Corporations And Of Other Property Sec. 962.
WebJan 24, 2024 · In the 2024 proposed regulations, the IRS and Treasury requested comments on the other provisions in the Internal Revenue Code that apply by reference to ownership … WebSection 958 - Rules for determining stock ownership. (a) Direct and indirect ownership. (1) General rule. For purposes of this subpart (other than section 960), stock owned means-. (A) stock owned directly, and. (B) stock owned with the application of paragraph (2). (2) Stock ownership through foreign entities.
Web(b) Constructive ownership. For purposes of sections 951(b), 954(d)(3), 956(c)(2), and 957, section 318(a) (relating to constructive ownership of stock) shall apply to the extent that the effect is to treat any United States person as a United States shareholder within the meaning of section 951(b), to treat a person as a related person within the meaning of section …
WebTitle 26 - INTERNAL REVENUE CODE Subtitle A - Income Taxes CHAPTER 1 - NORMAL TAXES AND SURTAXES Subchapter N - Tax Based on Income From Sources Within or Without the United States PART III - INCOME FROM SOURCES WITHOUT THE UNITED STATES Subpart F - Controlled Foreign Corporations Sec. 958 - Rules for determining … great clips surprise waddellWebJun 21, 2024 · Section 958 (a) (2) provides that stock owned, directly or indirectly, by or for a foreign corporation, foreign partnership, foreign trust, or foreign estate is considered to be … great clips suwanee ga 30024WebSection 958 provides rules for determining direct, indirect, and constructive stock ownership. Under section 958(a)(1), stock is considered owned by a person if it is owned directly or is owned indirectly through certain entities under section 958(a)(2). Under section 958(b), section 318 (relating to constructive ownership of stock) applies, great clips suwanee gaWebDec 17, 2024 · Historically, stock owned by an entity could be attributed to equity owners on a pro rata basis, and stock owned by equity owners could be attributed to the entity—forming the upward and downward attribution … great clips swansboro ncWebApr 7, 2024 · It is a United States person, and is treated as owning 100% of the stock of Foreign Subsidiary by application of the attribution rules in IRC §958(b). (Remember that the IRC §951(b) definition of “United States shareholder” requires “enough” stock to be owned using the definitions of ownership in either IRC §958(a) or IRC §958(b)). great clips swan rd tucson azWeb(b) Constructive ownership. For purposes of sections 951(b), 954(d)(3), 956(c)(2), and 957, section 318(a) (relating to constructive ownership of stock) shall apply to the extent that … great clips swanseaWebI.R.C. § 958(a)(3) Special Rule For Mutual Insurance Companies — For purposes of applying paragraph (1) in the case of a foreign mutual insurance company, the term “stock” shall … great clips swansea il hours