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.

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.

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.

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 …

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 …

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.

Aug 1, 2025 · IRC section 958 (b) (4) has been restored after being removed in the 2017 Tax Cuts and Jobs Act. Ownership of foreign corporation stock once again excludes stock constructively owned …

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.

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.