WebDec 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 … WebJan 1, 2024 · Internal Revenue Code § 958. Rules for determining stock ownership on Westlaw FindLaw Codes may not reflect the most recent version of the law in your …

LB&I Concept Unit - IRS

WebSep 2, 2024 · The bill includes new information reporting requirements for digital platform operators in the gig and sharing economy, the imposition of goods and services tax (GST) collection obligations on electronic marketplaces that facilitate accommodation and transportation services, and dual-resident company tax changes (largely in response to … WebSection 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, ontario take home pay calculator 2023

Subpart F — Controlled Foreign Corporations (Sections 951 to 965)

WebThe rules of section 958 (a) and this section provide a limited form of stock attribution primarily for use in determining the amount taxable to a United States shareholder under section 951 (a). These rules also apply for purposes of other provisions of the Code and regulations which make express reference to section 958 (a). 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 … WebI.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 … ionic covalent bonds worksheets