Section 9 Attribution of Ownership Between Partnerships and Partners

• Library: Bus Trans 2005

I.R.C. § 318(a)(2)(A) provides that stock owned, directly or indirectly, by or for a partnership, will be considered as being owned proportionately by the partners. I.R.C. § 318(a)(3)(A) provides that stock owned, directly or indirectly, by or for a partner will be considered as being owned by the partnership.

Treasury Regulation § 1.318-2(c) provides the following example:

A, an individual, has a 50 percent...