Total voting power and value.

(ii) Total voting power and value. In determining whether one foreign person owns 25 percent of the total voting power of all classes of stock of a corporation entitled to vote or 25 percent of the total value of all classes of stock of a corporation, consideration will be given to all the facts and circumstances of each case, under principles similar to 1.957-1(b)(2) (consideration of arrangements to shift formal voting power away from a foreign person).

Source

26 CFR § 1.6038A-1


Scoping language

None
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