Owner Taxpayer

Owner Taxpayer means the person subject to Federal income tax on net gain with respect to an API or an Indirect API during the taxable year, including an owner of a Passthrough Taxpayer unless the owner of the Passthrough Taxpayer is a Passthrough Entity itself or is excepted under 1.1061-3, (b), or (d).


26 CFR § 1.1061-1

Scoping language

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