The Attribution Rules (Portfolio 554)

Description

Bloomberg Tax Portfolio, The Attribution Rules, No. 554, examines the rules governing situations in which an individual or entity will be deemed to own stock held by another for purposes of various tax rules. The Portfolio describes in detail six sets of current attribution rules and reviews historically the now-repealed former foreign personal holding company rules:

• The constructive ownership rules of §267;
• The constructive ownership rules of §318;
• The personal holding company rules of §544;
• The now-repealed former foreign personal holding company rules of §554;
• The Subpart F constructive ownership rules in §958;
• The passive foreign investment company constructive ownership rules in §1297
• The consolidated return constructive ownership rules in §1563.

For each of the above provisions, the Portfolio analyzes the basic rules of the Internal Revenue Code section and covers the other sections of the Code in which those rules are used, detailing any differences in their application.This Portfolio may be cited as Brown, 554 T.M., The Attribution Rules.

Table of Contents

I. Introduction
II. The Constructive Ownership Rules of §267
III. Constructive Stock Ownership Rules of §318
IV. The Personal Holding Company Rules (Section 554)
V. The Foreign Personal Holding Company Rules (Former §554)
VI. The Subpart F Rules (§958)
VII. The Passive Foreign Investment Company (“PFIC”) (§1298)
VIII. The Controlled Group Rules (§1563)



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