Stock Attribution Rules Clause Samples
The Stock Attribution Rules clause defines how ownership of stock is determined by attributing shares held by certain related individuals or entities to a taxpayer. These rules typically apply in situations involving family members, partnerships, trusts, or corporations, where shares owned by one party may be considered as owned by another for tax or regulatory purposes. By clarifying indirect ownership, the clause prevents individuals or entities from circumventing ownership thresholds or restrictions, ensuring compliance with tax laws and regulatory requirements.
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Stock Attribution Rules. For purposes of this section, Code Section 318(a) applies to determine stock ownership. Stock underlying a vested option is considered owned by the individual who holds the vested option (and the stock underlying an unvested option is not considered owned by the individual who holds the unvested option). For purposes of the preceding sentence, however, if a vested option is exercisable for stock that is not substantially vested (as defined by Treasury Regulation Sections 1.83-3(b) and (j)), the stock underlying the option is not treated as owned by the individual who holds the option. In addition, mutual and cooperative corporations are treated as having stock for purposes of this subsection.