![]() |
Code of Federal Regulations (Last Updated: July 5, 2024) |
![]() |
Title 26 - Internal Revenue |
![]() |
Chapter I - Internal Revenue Service, Department of the Treasury |
![]() |
SubChapter A - Income Tax |
![]() |
Part 1 - Income Taxes |
![]() |
Personal Holding Companies |
§ 1.544-2 - Constructive ownership by reason of indirect ownership.
Latest version.
-
§ 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.