deemed-owned shares

(i)The term “deemed-owned shares” means, with respect to any person— (I)the stock in the S corporation constituting employer securities of an employee stock ownership plan which is allocated to such person under the plan, and (II)such person’s share of the stock in such corporation which is held by such plan but which is not allocated under the plan to participants. (ii)For purposes of clause (i)(II), a person’s share of unallocated S corporation stock held by such plan is the amount of the unallocated stock which would be allocated to such person if the unallocated stock were allocated to all participants in the same proportions as the most recent stock allocation under the plan.

Source

26 USC § 409(p)(4)(C)(i)


Scoping language

None: Default is title Scope
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