Partnerships, trusts and estates.
(k) Partnerships, trusts and estates. In applying the section 367(b) regulations, stock of a corporation that is owned by a foreign partnership, trust or estate shall be considered as owned proportionately by its partners, owners, or beneficiaries under the principles of 1.367(e)-1(b)(2). Stock owned by an entity that is disregarded as an entity separate from its owner under 301.7701-3 is owned directly by the owner of such entity. In applying 1.367(b)-5(b), the principles of 1.367(e)-1(b)(2) shall also apply to a domestic partnership, trust or estate.