8. Section 301.7701-2(c)(2)(iii): Special Rule for Business Entities That Make Purported Gifts
Par. 6. Section 301.7701-2 is amended by adding paragraph (c)(2)(iii) to read as follows:
* * * * *
(c) * * *
(2) * * *
(iii) Special rule for foreign business entities that make purported gifts. For the purposes of applying the rules of section 672(f)(4), a wholly owned business entity shall be treated as a corporation, separate from its single owner.
* * * * * Michael P. Dolan, Acting Commissioner of Internal Revenue.