Irc Section 318 A 3

3 attribution to partnerships estates trusts and corporations a to partnerships and estates stock owned directly or indirectly by or for a partner or a beneficiary of an estate shall be considered as owned by the partnership or estate.

Irc section 318 a 3. 318 a 4 options. For purposes of this clause a contingent interest of a beneficiary in a trust shall be. Internal revenue code section 318 a 1 constructive ownership of stock.

Section 318 a 3 a provides that stock owned directly or indirectly by or for a partner is considered as owned by the partnership. For purposes of those provisions of this subchapter to which the rules contained in this section are expressly made applicable 1 members of family. Under section 318 a 2 and 3 constructive ownership rules are established for partnerships and partners estates and beneficiaries trusts and beneficiaries and corporations and stockholders.

318 a 3 c to corporations if 50 percent or more in value of the stock in a corporation is owned directly or indirectly by or for any person such corporation shall be considered as owning the stock owned directly or indirectly by or for such person. I stock owned directly or indirectly by or for a beneficiary of a trust other than an employees trust described in section 401 a which is exempt from tax under section 501 a shall be considered as owned by the trust unless such beneficiary s interest in the trust is a remote contingent interest. An individual shall be considered as owning the stock owned directly or.

3 attribution to partnerships estates trusts and corporations a to partnerships and estates stock owned directly or indirectly by or for a partner or a beneficiary of an estate shall be considered as owned by the partnership or estate.