26 C.F.R. § 1.851-3 Rules applicable to section 851(b)(4).
Title 26 - Internal Revenue
In determining the value of the taxpayer's investment in the securities of any one issuer, for the purposes of subparagraph (B) of section 851(b)(4), there shall be included its proper proportion of the investment of any other corporation, a member of a controlled group, in the securities of such issuer. See example 4 in §1.851–5. For purposes of §§1.851–2, 1.851–4, 1.851–5, and 1.851–6, the terms “controls”, “controlled group”, and “value” have the meaning assigned to them by section 851(c). All other terms used in such sections have the same meaning as when used in the Investment Company Act of 1940 (15 U.S.C., chapter 2D) or that act as amended.
Title 26: Internal Revenue
PART 1—INCOME TAXES
REGULATED INVESTMENT COMPANIES AND REAL ESTATE INVESTMENT TRUSTS
§ 1.851-3 Rules applicable to section 851(b)(4).
