Andrew G. and Cecilia M. Vajna - Page 6




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          to such owners a pro rata share of subpart F income.  Section               
          958(a) gives the following guidance on the question of stock                
          ownership:                                                                  
                    SEC. 958(a).  Direct and Indirect Ownership.--                    
                           (1) General rule.--For purposes of this                    
                    subpart * * *, stock owned means--                                
                              (A) stock owned directly, and                           
                              (B) stock owned with the                                
                           application of paragraph (2).                              
                           (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 * * * 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.                                                      
               In addition, regulations promulgated under section 958                 
          provide rules of application supplementing the statutory text:              
               Amount of interest in foreign corporation, foreign                     
               partnership, foreign trust, or foreign estate.  The                    
               determination of a person’s proportionate interest in a                
               foreign corporation, foreign partnership, foreign                      
               trust, or foreign estate will be made on the basis of                  
               all the facts and circumstances in each case.                          
               Generally, in determining a person’s proportionate                     
               interest in a foreign corporation, the purpose for                     
               which the rules of section 958(a) and this section are                 
               being applied will be taken into account.  Thus, if the                
               rules of section 958(a) are being applied to determine                 
               the amount of stock owned for purposes of section                      
               951(a), a person’s proportionate interest in a foreign                 
               corporation will generally be determined with reference                
               to such person’s interest in the income of such                        
               corporation.  If the rules of section 958(a) are being                 




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