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(2) Stock ownership through foreign
entities.--For purposes of subparagraph (B)
of paragraph (1), stock owned, directly or
indirectly, by or for a foreign corporation,
foreign partnership, or foreign trust or
foreign estate (within the meaning of section
7701(a)(31)) shall be considered as being
owned proportionately by its shareholders,
partners, or beneficiaries. 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.
* * * * * * *
(b) Constructive Ownership.--For
purposes of sections 951(b), 954(d)(3),
956(b)(2), and 957, section 318(a) (relating
to constructive ownership of stock) shall
apply to the extent that the effect is to
treat any United States person as a United
States shareholder within the meaning of
section 951(b), to treat a person as a
related person within the meaning of section
954(d)(3), to treat the stock of a domestic
corporation as owned by a United States
shareholder of the controlled foreign
corporation for purposes of section
956(b)(2), or to treat a foreign corporation
as a controlled foreign corporation under
section 957, except that--
(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
or by a resident alien individual.
(2) In applying subparagraphs
(A), (B), and (C) of section
318(a)(2), if a partnership,
estate, trust, or corporation owns,
directly or indirectly, more than
50 percent of the total combined
voting power of all classes of
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