{"data":{"id":"us/26-cfr-1.544-2","jurisdiction":"us","citation":"26 CFR 1.544-2","heading":"-2 Constructive ownership by reason of indirect ownership.","body":"The following example illustrates the application of section 544(a)(1), relating to constructive ownership by reason of indirect ownership:\nExample.\nA and B, two individuals, are the exclusive and equal beneficiaries of a trust or estate which owns the entire capital stock of the M Corporation. The M Corporation in turn owns the entire capital stock of the N Corporation. Under such circumstances the entire capital stock of both the M Corporation and the N Corporation shall be considered as being owned equally by A and B as the individuals owning the beneficial interest therein.","path":["Title 26—Internal Revenue","CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY","SUBCHAPTER A—INCOME TAX","PART 1—INCOME TAXES"],"source_url":"https://www.ecfr.gov/api/versioner/v1/full/2026-08-25/title-26.xml","current_through":"2026-08-25","vintage":"","retrieved_at":"2026-08-27T02:25:11Z","sha256":"0ffb0167d3611b3b87c315087b1d91b3752bfe846642ca2c64b072e0b1f07b75","source_id":"us-cfr","stale":true,"prev":"us/26-cfr-1.544-1","next":"us/26-cfr-1.544-3"},"notice":"GroundRules: Original legal text. Not legal advice."}