WebFor purposes of this title, the term “United States shareholder” means, with respect to any foreign corporation, a United States person (as defined in section 957(c)) who owns (within the meaning of section 958(a)), or is considered as owning by applying the rules of ownership of section 958(b), 10 percent or more of the total combined voting power of all … Webownership. 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, with certain modifications, to the extent that the effect is to treat any U.S. person as a

Federal Register :: Ownership Attribution Under Section 958 for ...

Web9 IRC §951(a)(2). 10 IRC §958(a). 11 Treas. Reg. §1.958-1(c)(2); FSA 199952014. 12 Treas. Reg. §1.958-1(d) Example (3) illustrated the application of indirect ownership rules by reference to a trust that had three beneficiaries who had fixed and equal shares of trust income and principal, but most foreign trusts are wholly discretionary. WebSection 958 (a) provides that, for purposes of sections 951 to 964 (other than sections 955 (b) (1) (A) and (B) and 955 (c) (2) (A) (ii) (as in effect before the enactment of the Tax … circot yarn

section 958(b)(4) of the Internal Revenue Code (“Code”) to

WebJun 21, 2024 · A “controlling domestic shareholder group” is defined as two or more CFCs if more than 50 percent of the stock (by voting power) of each CFC is owned (within the … WebUnder one rule in IRC Section 958 (a) (2), a shareholder of a corporation, a partner in a partnership, or a beneficiary of a foreign entity (collectively, equityholder) is treated as … WebFeb 1, 2024 · Sec. 958 (a) provides that stock owned means both stock owned directly and stock owned indirectly through foreign entities. Sec. 958 (b) provides that, for purposes of certain sections and with certain modifications, the constructive ownership rules of Sec. 318 apply when determining stock ownership. diamond cashback credit card