In the case of a partnership, stock owned by the partnership is deemed to be owned proportionately by its partners. The upward attribution rules (i.e., attribution from an entity up to its owners) are found in Section 318(a)(2). This article briefly summarizes the attribution rules applicable to partnerships and corporations under Section 318 and provides some practical tips for dealing with the rules. clients investing in South Florida and elsewhere in the U.S. international tax community, is mostly due to the implications that these rules now have for common investment structures utilized by non-U.S. The increased attention, at least from the U.S. Attribution rules have always been relevant for tax planning purposes, but ever since the passage of the 2017 Tax Cuts and Jobs Act (the "2017 Tax Act"), a particular set of attribution rules has received a renewed amount of attention.
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