Yesterday the IRS published a new practice unit titled “IRC 958 Rules for Determining Stock Ownership.”
The direct and indirect ownership rules in Code §958 are important for purposes of determining, among other things:
The practice unit discusses the downward attribution rules and the repeal of Code §958(b)(4). The practice unit includes 16 examples with structure charts showing how the ownership attribution rules work.
This new practice unit has been added to our Practice Units By Topic page.