Category : Aggregation Rules

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A 5-percent shareholder generally means any person who owns 5 percent or more (by fair market value) of the stock of the loss corporation. Under Treas. Reg. § 1.382-2T(g)(1), the term “5-percent shareholder” includes  (i) an individual who owns either a direct ownership interest in the stock of the loss corporation of 5 percent or more, ..

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