Entries by Manager

§318 Option Definition | US International Tax Lawyer & Attorney

This article continues our series of articles on the IRC (Internal Revenue Code) §318 constructive ownership rules. In this article, I would like to introduce the readers to the infamous §318 option attribution rules. Before we delve into the discussion of the constructive ownership rules for options, however, it is important to understand what “option” […]

§318 Upstream Corporate Attribution | International Tax Lawyers Florida

In a previous article, I discussed the rules for the downstream attribution of corporate stocks under the IRC (Internal Revenue Code) §318. Today, I would like to discuss the §318 upstream corporate attribution rules. §318 Upstream Corporate Attribution: Two Types of Attribution There are two types of §318 corporate attribution rules: downstream and upstream. Under […]

§318 Downstream Corporate Attribution | Corporate Tax Lawyer & Attorney

This article continues a series of articles on the constructive ownership rules of the IRC (Internal Revenue Code) §318. Today, we will discuss corporate attribution rules, even more specifically the §318 downstream corporate attribution rules. §318 Downstream Corporate Attribution: Two Types of Attribution There are two types of §318 corporate attribution rules: downstream and upstream. […]