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.

Therefore, for purposes of sections 951 and 951A, USP is treated as owning 95% of the FC stock under section 958 (a), and Individual A is treated as owning 5% of the FC stock under section 958 (a).

Under paragraph (a) (2) of § 1.958-1, A and B are considered as owning 3 percent (5 percent of 60 percent) and 15 percent (25 percent of 60 percent), respectively, of the stock in N Corporation.

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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 …

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.

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