Section 8 Family Attribution Rules

• Library: Bus Trans 2005

I.R.C. § 318(a)(1) provides that an individual will be considered as owning the stock owned, directly or indirectly, by or for the individual’s:

• spouse, other than a spouse who is legally separated under a decree of divorce or separate maintenance

• children, including those legally adopted

• grandchildren; and

• parents

There is no attribution under I.R.C. § 318(a)(1) between brothers and sisters, and while there is attribution to grandparents, there is no attribution from grandparents to...