Stock considered to be owned by a person by reason of the application of the preceding sentence shall, for purposes of applying such sentence, be treated as actually owned by such person.

Internal Revenue Code (“IRC”) 958 provides rules for determining stock ownership of a corporation for purposes of IRC 951 through 965 (Subpart F), except for IRC 960.

4 days ago · O sorteio do concurso 2.958 da Mega-Sena foi realizado na noite deste sábado (10), em São Paulo. Nenhuma aposta acertou as seis dezenas, e o prêmio para o próximo sorteio …

Dec 14, 2025 · Caution: Code section 958 (b), prior to amendment by P.L. 119-21, is effective for tax years of foreign corporations beginning before January 1, 2026. (b) Constructive ownership.

Stock considered to be owned by a person by reason of the application of the preceding sentence shall, for purposes of applying such sentence, be treated as actually owned by such person.

Stock considered to be owned by a person by reason of the application of the preceding sentence shall, for purposes of applying such sentence, be treated as actually owned by such person.

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The IRS Large Business and International (LB&I) division publicly released a "practice unit"-part of a series of IRS examiner "job aides" and training materials intended to describe for IRS agents …

Aug 30, 2022 · The practice unit discusses the downward attribution rules and the repeal of Code §958 (b) (4). The practice unit includes 16 examples with structure charts showing how the …

Therefore, for purposes of sections 951 and 951A, USP is treated as owning 95% of the FC stock under section 958 (a), and Individual A is treated as owning 5% of the FC stock under section …