In addition, the number of disputes and potential double taxation will likely increase due to different interpretations of what constitutes "negotiating material elements of contracts" or in the application of modified profit attribution rules
that are still to be determined.
SJ: My suggestion for adding to or deleting from the Internal Revenue Code, outside of controversial political/policy matters, would be to have, if possible, as a technical matter, a uniform set of attribution rules
to replace the many, different, complex attribution rules
that are scattered throughout the Code.
1298(a) provides attribution rules
that treat a person as a U.
apply to treat certain family members as owners for this purpose.
When determining whether an S corporation owner is a 2% shareholder, it's important to consider the family attribution rules
These attribution rules
also apply to any taxable capital gains or allowable capital losses generated by the transferred property.
Under Section 382, stock ownership would be determined under complex attribution rules
pursuant to the Tax Code and generally includes shares held directly, indirectly (through intervening entities) and constructively (by certain related parties and certain unrelated parties acting as a group).
The Income Tax Act (the Act) contains various attribution rules
that apply when an individual transfers property to his or her spouse (or common law partner).
Lobbied successfully to change the Federal Communication Commission's attribution rules
requiring a cooperative to include a director's outside income in the company's revenues when applying for spectrum bidding credits.
If the stock redemption plan is selected for a family-owned corporation, the possible application of the attribution rules
of Internal Revenue Code Section 318 must be considered.
The term accountable refers to attribution rules
established in the first Strategic Arms Reduction Treaty--START I--signed by the U.
Disproportionate redemptions are further complicated by the application of the attribution rules
of Section 318, which treat shareholders as owning the shares of certain family members and other entities as well as their own shares (Example 5).