26 U.S. Code § 958 - Rules for determining stock ownership
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.
Sec. 958. Rules For Determining Stock Ownership - Bloomberg Law
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.
Internal Revenue Code (“IRC”) 958 provides rules for determining stock ownership of a corporation for purposes of IRC 951 through 965 (Subpart F), except for IRC 960.
Code Sec. 958 | Tax Notes
Dec 14, 2025 · Caution: Code section 958 (b), prior to amendment by P.L. 119-21, is effective for tax years of foreign corporations beginning before January 1, 2026. (b) Constructive ownership.
26 U.S.C. § 958 - U.S. Code Title 26. Internal Revenue Code ...
Jan 1, 2024 · (1) In applying paragraph (1) (A) of section 318 (a), stock owned by a nonresident alien individual (other than a foreign trust or foreign estate) shall not be considered as owned by a citizen …
26 U.S.C. § 958 (2023) - Rules for determining stock ...
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.
Section 958: Downward attribution rules affect filing ...
Jun 3, 2025 · Changes made to Internal Revenue Code (IRC) Section 958 by the Tax Cuts and Jobs Act (TCJA) appear to have gone farther than Congress intended toward removing safeguards against …