1298(a)(3), it is treated as
owning its proportionate share of the stock owned directly or indirectly by FP (i.e.,US1 owns 30% of G1).
Some form of an antidividend stripping rule is necessary to deal with the situation where the
owning members retain some stock of the former subsidiary member.
person that holds an option to acquire foreign company stock is treated as
owning the stock subject to the option for purposes of determining' whether the option holder is a U.S.
For tax years beginning before 1997, an S corporation was prohibited from
owning 80% or more of another corporation's stock.
Had M and P purchased the residence as tenants in common, with M
owning 44.45% ($200,000/$450,000) and P
owning 55.55% ($250,000/$450,000), both M and P could have deferred their entire gains.
303 are not limited to taxpayers
owning interests in closely held corporations, but could also be used when the stock is widely held and publicly traded.
Owning 80% of the voting power or value of each class of stock is not necessary.
transferor
owning at least 5% of the foreign transferee corporation.
[] Dividends Reduced from 10% to 5% on dividends paid to a corporation
owning at least 10% or more of the voting stock of the payer, unless the payer is a Canadian nonresident-owned investment corporation, a regulated investment company (RIC) or a real estate investment trust (REIT).
Under the constructive ownership rules, Martina is treated as
owning an additional 50% of Land Racket - the 37.5% owned by her brothers and sister (Ivan, Boris and Chrissy), and the 12.5% owned by her spouse (Jimmy).
318(a)(4) can treat a nonshareholder as
owning shares or treat a shareholder as
owning more shares than he actually owns.
