Detailed analysis. Introduction -- General pattern of personal holding company provisions -- Corporations excepted from personal holding company status -- Definition of a personal holding company: the income test -- Definition of a personal holding company: the stock ownership test -- Attribution of ownership under [section] 544 -- Corporations filing consolidated returns -- Return requirement for personal holding companies -- Computation of the personal holding company tax -- Computing undistributed personal holding company income -- Dividends paid deduction -- Working papers.
Summary
" ... considers all aspects of the personal holding company tax. In general terms, the tax is imposed on corporations which are more than 50% owned by five or fewer individuals (the ownership test) and which derive 60% or more of their income from personal holding company sources (the income test)."
