§ 1.544-2. Constructive ownership by reason of indirect ownership.
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/us/cfr/t26/s§ 1.544-2·A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
The following example illustrates the application of section 544(a)(1), relating to constructive ownership by reason of indirect ownership: Example.A and B, two individuals, are the exclusive and equal beneficiaries of a trust or estate which owns the entire capital stock of the M Corporation. The M Corporation in turn owns the entire capital stock of the N Corporation. Under such circumstances the entire capital stock of both the M Corporation and the N Corporation shall be considered as being owned equally by A and B as the individuals owning the beneficial interest therein.