A United States person is not treated as owning a foreign person's stock
What the document says“Subparagraphs (A), (B), and (C) of section 318(a)(3) shall not be applied so as to consider a United States person as owning stock which is owned by a person who is not a United States person.”
The section inserts a new paragraph (4) into section 958(b) of the Internal Revenue Code of 1986 barring subparagraphs (A), (B) and (C) of section 318(a)(3) from being applied so as to treat a United States person as owning stock owned by a person who is not a United States person, and changes the last sentence of section 958(b) to name paragraphs (1) and (4).
What the document actually says“Subparagraphs (A), (B), and (C) of section 318(a)(3) shall not be applied so as to consider a United States person as owning stock which is owned by a person who is not a United States person.”
Three parts of an ownership rule are switched off in one case. They may not treat a United States person as owning a foreign person's shares.
That kind of treatment is called downward attribution. It pulled foreign firms into United States tax rules. This bar shuts that route.
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