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TREASURY REGULATIONS


Index  » Subchapter A  » Reg. 1.544-2

Reg. 1.544-2
Constructive ownership by reason of indirect ownership

January 14, 2024


§ 1.544-1 « Browse » § 1.544-3

See related I.R.C. 544

Treas. Reg. § 1.544-2.  Constructive ownership by reason of indirect ownership

The following example illustrates the application of section 544(a)(1), relating to constructive ownership by reason of indirect ownership:

Example.

A and B, two individuals, are the exclusive and equal beneficiaries of a trust or estate which owns the entire capital stock of the M Corporation. The M Corporation in turn owns the entire capital stock of the N Corporation. Under such circumstances the entire capital stock of both the M Corporation and the N Corporation shall be considered as being owned equally by A and B as the individuals owning the beneficial interest therein.

 

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