26 U. S. Code § 958 - Rules for determining stock 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
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
Code Sec. 958 | Tax Notes Paragraph (1) shall not apply for purposes of section 956 (c) (2) to treat stock of a domestic corporation as not owned by a United States shareholder Caution: Code section 958 (b) (4), amended and added by P L 119-21, is effective for tax years of foreign corporations beginning after December 31, 2025 (b) Constructive ownership
Section 958: Downward attribution rules affect filing . . . 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
26 U. S. C. § 958 (2023) - Rules for determining stock . . . 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