@gugu I agree with Katie.
Related party provisions:
– section 267 prevents taxpayers from shifting ownership % of stock or property to a related person or entity in an effort to take advantage of beneficial provisions of the IRS while still controlling their original interest
– several “constructive ownership” rules
Definition of related parties:
– brothers/sisters, husband/wife, ancestors and lineal descendants (grandfather, father, son)
– entities that are more than 50% owned directly/indirectly by individuals, corporations, trusts/partnerships
– controlled groups (any two corporations, partnerships, etc.) both more than 50% owned by the same party
– various relationships between trusts, grantors, fiduciaries, etc.
– tax-exempt organizations and person controlling directly/indirectly such organizations
BEC = 72 (6/08/16)
FAR = ?
REG = ?
AUD = ?