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—

(A) stock owned directly, and

(B) stock owned with the application of paragraph (2).

(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.

(3) Special rule for mutual insurance companies. For purposes of applying paragraph (1) in the case of a foreign mutual insurance company, the term “stock” shall include any ...