Prop. Treas. Reg. § 301.7701-2 Business entities; definitions.

Proposed 1997-06-05 · REG-252487-96 · 62 FR 30785 · Interprets § 7701 · Would amend § 301.7701-2

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.