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Rev. Rul. 70-469 - Nominal Ownership - Affiliated Group Definition

2024-10-19

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Today we published a chart of Rev. Rul. 70-469.

Rev. Rul. 70-469 concludes that a single share of stock of a subsidiary corporation that was transferred away by the parent corporation to a nominee continued to be beneficially owned by the parent. In addition, the parent “directly” owned the share. As a result, the subsidiary corporation was 80% owned and was part of the parent corporation’s affiliated group.

Tags: Charts - Situational Charts, Authority - Revenue Rulings, Other - Form vs. Substance