D*********h 发帖数: 209 | 1 All right tax experts! A good question for you, I am sure you heard people
say indirectly ownership, constructive ownership, ownership by attribution A
LOT! Is it right to say (for Subchapter C at least), all three are all
referring to IRC 318(a)(2)(C)? If not, what are the differences of the three
terms? Many thanks in advance. | v********e 发帖数: 378 | 2 318(a)(2)(C) is an attributing rule from a corporation. The difference is
that indirect and contructive onwerships are real ownership but by
attribution is "imputed", which is only relevant for testing ownership
purposes. |
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