(a) In general. — For purposes of this part:(1) Attribution from partnerships, estates, trusts, and corporations. —(A) From partnerships and estates. — Stock owned directly or indirectly by or for a partner or beneficiary of an estate shall be considered as owned by the partnership or estate.(B) For trusts. —(i) Stock owned directly or indirectly by or for a beneficiary of a trust (other than a trust exempted from taxation under § 30391 of this title) shall be considered as owned by the trust, unless the interest of the beneficiary in the trust is a remote contingent interest. For purposes of this subparagraph, a contingent interest shall be considered as remote if, under the utmost exercise of discretion by the trustee in favor of the beneficiary, the value of said interest, computed actuarially, is of five percent (5%) or less of the value of the property of the trust.(ii) Stock owned directly or indirectly by or for a person who is considered to be the owner of any portion of a trust under §§ 30411—30419 of this title (related to grantors and others treated as owners) shall be considered as owned by the trust.(iii) For corporations.

dered to be the owner of any portion of a trust under §§ 30411—30419 of this title (related to grantors and others treated as owners) shall be considered as owned by the trust.(iii) For corporations. — If ten percent (10%) or more in value of the stock in a corporation is owned directly or indirectly by or for any person, it shall be considered that said corporation possesses the stock owned directly or indirectly by or for said person. History —Jan. 31, 2011, No. 1, § 1082.03, retroactive to Jan. 1, 2011.