View all text of Subjgrp 8 [§ 1.541-1 - § 1.547-7]
§ 1.544-2 - Constructive ownership by reason of indirect ownership.
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.