TAX 9866 Lecture Notes - Lecture 7: Mutual Fund, Real Estate Investment Trust
Document Summary
For purposes of 302, we have to apply attribution. There are basic concepts to understand when testing if you meet qualification rules for. It"s not enough that my interest/shares of stock were decreased below requisite requirements. Have to look at what other stock deemed to be owned. Deemed transactions: 311(b) = deemed sale as tho sold even though no actual sale; corp recognizes gain. Partner or significant sh to entity attribution (corporate vs. partnership) If i could plan the sales of my shares to closely corp meet mechanical test of 302, that might be easy if didn"t have to worry about 318 attribution. Example: i have two minor children, b/c minor mom & dad are in charge of money/control shares of stock. I own 50 shares, give each daughter 25 shares. Have company redeem my 50% of my shares. Go thru 302 mechanical test; and say yes, i get sale exchange treatment.
