Textron Inc. and Subsidiary Companies - Page 26




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                         income withdrawn (as determined                              
                         under section 955(a)(3)) for the                             
                         taxable year, as                                             
                              (B) the part of such year                               
                         during which the corporation is a                            
                         controlled foreign corporation                               
                         bears to the entire year.                                    
                         (4) Limitation on pro rata share of                          
                    investment in United States property.- For                        
                    purposes of paragraph (1)(B), the pro rata                        
                    share of any United States shareholder in the                     
                    increase of the earnings of a controlled                          
                    foreign corporation invested in United States                     
                    property shall not exceed an amount (A) which                     
                    bears the same ratio to his pro rata share of                     
                    such increase (as determined under section                        
                    956(a)(2)) for the taxable year, as (B) the                       
                    part of such year during which the                                
                    corporation is a controlled foreign                               
                    corporation bears to the entire year.                             
                    (b) United States Shareholder Defined.--For                       
               purposes of this subpart, the term “United States                      
               shareholder” means, with respect to any foreign                        
               corporation, a United States person (as defined in                     
               section 957(c)) who owns (within the meaning of section                
               958(a)), or is considered as owning by applying the                    
               rules of ownership of section 958(b), 10 percent or                    
               more of the total combined voting power of all classes                 
               of stock entitled to vote of such foreign corporation.                 
                              *    *    *    *    *    *    *                         
               SEC. 958.  RULES FOR DETERMINING STOCK OWNERSHIP.                      
                    (a)  Direct and Indirect Ownership.--                             
                         (1) General rule.--For purposes of this                      
                    subpart (other than sections 955(b)(1)(A) and                     
                    (B), 955(c)(2)(A)(ii), and 960(a)(1)), stock                      
                    owned means                                                       
                              (A) stock owned directly, and                           
                              (B) stock owned with the                                
                         application of paragraph (2).                                





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