958(a)(2), US1 and US2 are treated as owning the CFC stock in proportion to their FP interests.
The outside basis of US1 and US2 is increased by their distributive shares of the dividend income, or $5 each.
Therefore, most people who have retinitis pigmentosa and hearing loss probably have US1
The analysis differs depending on whether US1 and US2 file separate or consolidated returns.
Using the above example, Situations 1 and 2 below show what happens if US1 and US2 do not file consolidated returns.
The first alternative uses a "bottom-up" analysis to ultimately treat US1 as an owner of J1.
This analysis starts with US1 and moves down the ownership chain.
corporation, US1, has an option to purchase all of the FC1 stock owned by FP2, but otherwise does not own any FC1 or FC2 stock.
Thus, in Example 2, FC1 is a CFC and, even though US1 is a U.
Effective immediately, US1 will offer private label, automotive aftermarket warranty and service plans, designed and administered by Warrantech, to its current and prospective client roster.
US1 serves more than 150 new and pre-owned car dealers in North and South Carolina, Georgia, Florida, Missouri, Nebraska and Louisiana, and plans to expand its private label warranty nationwide.
, there is currently a sign that provides an actual number of fatalities as they occur.