Section 7 Scope of I.R.C. 318

• Library: Bus Trans 2005

The stock ownership attribution rules of I.R.C. § 318 are expressly made applicable to the I.R.C. § 302(b) stock redemption provisions. The ownership attribution rules were enacted in 1954 to eliminate the uncertainty of prior law in determining when to consider other ownership in determining whether a redemption qualifies as a capital transaction.

I.R.C. § 318 is not an operative tax section. It contains the rules that apply and relate...