The commenter recommended that the exception be limited to scenarios in which the related party is an individual or an RPE and that the term "related party" be defined with reference to existing
attribution rules under Sec.
These are, in some sense,
attribution rules, pursuant to which the account of an entity is attributed to the United States person.
Are the current profit
attribution rules fit for purpose'?
shareholders that own, or are considered to own, as a result of the
attribution rules, 10% or more of the voting power or value of the stock of a non-U.S.
In the ASG context, entity, trust and family
attribution rules apply, but with certain key differences from the rules used in the controlled group context, so expert advice is advised.
In its report, Rand recommends the creation of an independent international body, perhaps financed by top tech companies that would work out a set of
attribution rules and apply them to analysis of high-profile breaches, followed by a peer review process.
[section]2701's ownership
attribution rules and ordering rules set forth in Treas.
Careful planning is necessary to ensure the
attribution rules (discussed below) are addressed.
1298(a) provides
attribution rules that treat a person as a U.S.
Individual patients' experiences then are aggregated up to the provider level through some type of patient
attribution rule. There are two main dimensions along which
attribution rules can be classified.
Under the family
attribution rules, Adam is deemed to own 100% of the company's stock (his 1% plus Anna's 99%) for purposes of the 2% rule.
