This memorandum from the Office of Chief Counsel, IRS, addresses the application of grantor trust rules and ownership attribution rules under §§ 267 and 707(b)(1)(A). It discusses whether grantor trusts are disregarded as separate entities for federal income tax purposes, the disallowance of short-term capital losses under these sections, and the applicability of § 165. The document includes a detailed analysis of ownership structures, transactions, and relevant tax laws and rulings.
documents/EFTA01106843.pdf
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