CorpTax-Slides for Chapter 4.f13

Estates trusts and corporations 318 a2 contd

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Unformatted text preview: eir actuarial interests in the trust in 9 Attribution From Partnerships, Estates, Trusts, and Corporations—§ 318 (a)(2) (Cont’d) Corporation—stock owned by the corporation is Corporation—stock constructively owned by its shareholders in proportion proportion to the value of stock owned by the shareholder to However, constructive ownership applies only if the However, shareholder owns 50% or more in value of the corporation’s stock corporation’s 10 Attribution From Partnerships, Estates, Trusts, and Corporations—§ 318 (a)(2) (Cont’d) Example: A B 70% 30% X 100 Y 11 Attribution From Partnerships, Estates, Trusts, and Corporations—§ 318 (a)(2) (Cont’d) Example: Husband Wife 40 % 20 % X 80 Y 12 Attribution To Partnerships, Estates, Trusts, and Corporations—§ 318 (a)(3) Partner—stock owned by the partner is constructively Partner—stock owned by the partnership owned Beneficiary—stock owned by a beneficiary of an estate Beneficiary—stock is constructively owned by the estate is 13 Attribution To Partnerships, Estates, Trusts, and Corporations—§ 318 (a)(3) (Cont’d) Beneficiary—stock owned by a beneficiary of a trust is Beneficiary—stock constructively owned by the trust unless the beneficiary’s interest in the trust is a remote contingent interest contingent A remote contingent interest is an interest the actuarial remote value of which is 5% or less of the value of the trust property property 14 Attribution To Partnerships, Estates, Trusts, and Corporations—§ 318 (a)(3) (Cont’d) Shareholder—stock owned by a shareholder is Shareholder—stock constructively owned by the corporation if the shareholder owns 50% or more in value of the corporation’s stock corporation’s 15 Prohibited Attribution—§ 318 (a)(5)(C) Stock owned constructively by a partnership, estate, Stock trust, or corporation by the application of § 318(a)(3) (attribution to entity) will not be considered as owned to for purposes of applying § 318 (a)(2) (attribution from from entity) entity) 16 Prohibited Attributio...
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