Attribution Rules

Attribution Rules

Attribution Rules means:
rules that create ownership by attributing stock to one party even though the shares are legally owned by another party; often called constructive ownership of stock. See also related parties. Rule 1. Stock directly or indirectly owned by or for a corporation, partnership, estate, or trust is considered owned by or for its shareholders, partners, or beneficiaries.

Rule 2. An individual is considered to own stock that is directly or indirectly owned by or for his or her family. Family includes only brothers, sisters, half-brothers, half-sisters, spouses, ancestors, and lineal descendants.

Rule 3. An individual owning any stock in a corporation is considered to own the stock that is directly or indirectly owned by his or her partner.

Rule 4. Stock constructively owned by a person under Rule 1 is treated as actually owned by that person for the purposes of applying Rules 2 and 3. Stock constructively owned by a person under Rule 2 or 3 is not treated as owned by that person for again applying Rule 2 or 3. Former IRC (check if this IRC provision is current here) §§267(c), 318, and 544(a).


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