26 U. S. Code § 958 - Rules for determining stock ownership Amendment by Pub L 94–455 applicable to taxable years of foreign corporations beginning after Dec 31, 1975, and to taxable years of United States shareholders within which or with which such taxable years of such corporations end, see section 1021 (c) of Pub L 94–455, set out as a note under section 956 of this title
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IRC 958 Rules for Determining Stock Ownership 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
Final Sec 958 regs and proposed PFIC regs with key changes: PwC Treasury and the IRS on January 25 published final regulations under Section 958 on determining stock ownership and proposed regulations regarding the treatment of domestic partnerships and S corporations that own stock of passive foreign investment companies (PFICs) and their domestic partners and shareholders
Section 958: New downward attribution rules affect filing requirements Changes made to Internal Revenue Code (IRC) Section 958 by the Tax Cuts and Jobs Act (TCJA) appear to have gone farther than Congress intended toward removing safeguards against downward attribution of ownership interests in non-U S entities
Code Sec. 958 | Tax Notes (1) In applying paragraph (1) (A) of section 318 (a), stock owned by a nonresident alien individual (other than a foreign trust or foreign estate) shall not be considered as owned by a citizen or by a resident alien individual