§ 246A(c)(1)

debt financed portfolio stock

UNDECIDED

0 of 3 settled

  1. 1

    § 246A(c)(1)

    ALL OF
    “any portfolio stock” unless Step 2 stock is not portfolio stock UNDECIDED
    “at some time during the base period there is portfolio indebtedness with respect to such stock” needs Step 3 is portfolio indebtedness UNDECIDED
  2. 2

    § 246A(c)(2)

    stock is not portfolio stock

    ANY OF

    The term “portfolio stock” means any stock of a corporation unless—

    “any stock of a corporation” Opening words
    “as of the beginning of the ex-dividend date, the taxpayer owns stock of such corporation— possessing at least 50 percent of the total voting power of the stock of such corporation, and having a value equal to at least 50 percent of the total value of the stock of such corporation, or” § 246A(c)(2)(A)
    “as of the beginning of the ex-dividend date— the taxpayer owns stock of such corporation which would meet the requirements of subparagraph (A) if “20 percent” were substituted for “50 percent” each place it appears in such subparagraph, and stock meeting the requirements of subparagraph (A) is owned by 5 or fewer corporate shareholders.” § 246A(c)(2)(B)
  3. 3

    § 246A(d)(3)(A)

    is portfolio indebtedness

    ALL OF
    “any indebtedness directly attributable to investment in the portfolio stock.”