2024-10-19
Today we published a chart of Rev. Rul. 70-469.
Rev. Rul. 70-469 concludes that a single share of stock of a subsidiary corporation that was transferred away by the parent corporation to a nominee continued to be beneficially owned by the parent. In addition, the parent “directly” owned the share. As a result, the subsidiary corporation was 80% owned and was part of the parent corporation’s affiliated group.