Page 42 - Large Business IRS Training Guides
P. 42

Related Party
                                                                                      (cont’d)









               •	  Section 318 attribution rules apply
                                                                                              except –

                      •	  “10 percent” replaces
                                                                      “50 percent” in section

                           318(a)(2)(C), and


                      •	  Sections 318(a)(3)(A), (B), and (C)  are not applied so

                           as to consider a United States person as owning


                           stock  that is owned by a person who is not a United

                           States person


               •	  Special
                                     rules apply for partnerships (discussed
                     further below)















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