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.
Finally, the notice provides taxpayers targeted relief from certain unintended regulatory and reporting consequences arising from a change to existing stock attribution rules
in the recent tax legislation.
The controlled group attribution rules
are complex and can only be touched on here.
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.
The family stock ownership attribution rules
do not come into play because H and W are no longer married (and H has no attributed stock ownership under any other provision of Sec.
The agency did not approve to waive its JSA attribution rules
for KWCH-DT and KDCU-DT, but granted a temporary waiver and gave Gray one year to un-wind the JSA.
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.
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.
There are two main dimensions along which attribution rules
can be classified.
When determining whether an S corporation owner is a 2% shareholder, it's important to consider the family attribution rules