Constructive Ownership Rules definition
Constructive Ownership Rules means the ownership attribution rules of Section 318(a) of the Code, as modified by Section 856(d)(5) of the Code.
Constructive Ownership Rules. The constructive ownership rules of Section 318 of the Code which require an individual to be treated as owning the corporate stock owned directly or indirectly by the individual, the individual's spouse, children, grandchildren and parents and the individual's proportionate share of stock held by S corporations of which the individual is a shareholder, partnerships of which the individual is a partner, trusts of which is a beneficiary of more than 5% of the value thereof and C corporations of which the individual is a 50% or more shareholder by value. A Person is also treated as owning any stock with respect to which the Person holds options to purchase. In general, corporations, partnerships and trusts are treated as owning stock held by their shareholders, partners and beneficiaries respectively.
Constructive Ownership Rules. The constructive ownership rules of Section 318 of the Code which require an individual to be treated as owning the corporate stock owned directly or indirectly by the individual the individual's spouse, children, grandchildren and parents and the individual's proportionate share of stock held by S corporations of which the individual is a shareholder, partnerships of which the individual is a partner, trusts of which is a beneficiary of