TITLE 26. INTERNAL REVENUE CODE § 958. Rules for determining stock ownership., 26 USCS § 958
Summary
(a) Direct and indirect ownership.
(1) General rule. For purposes of this subpart [26 USCS §§ 951 et seq.] (other than section 960 [26 USCS § 960]), stock owned means—
(2) Stock ownership through foreign entities. For purposes of subparagraph (B) of paragraph (1), stock owned, directly or indirectly, by or for a foreign corporation, foreign partnership, or foreign trust or foreign estate (within the meaning of section 7701(a)(31) [26 USCS § 7701(a)(31)]) shall be considered as being owned proportionately by its shareholders, partners, or beneficiaries. 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.