Legal Definitions - attribution

Definition: Attribution is the process of assigning someone's or something's stock ownership to a related family member or entity for tax purposes. This process is outlined in the Internal Revenue Code.

Example: Let's say John owns 50% of a company's stock, and his wife Jane owns 30% of the same company's stock. According to the attribution rules, John is considered to own not only his own 50% but also Jane's 30%, making his total ownership 80%. This is important for tax purposes because it affects how much of the company's income is attributed to John and Jane for tax purposes.

Explanation: The example illustrates how attribution works in practice. Even though Jane technically owns 30% of the company's stock, the attribution rules consider her ownership as belonging to John as well. This is because John and Jane are related, and the IRS wants to prevent people from avoiding taxes by transferring ownership to family members. By attributing Jane's ownership to John, the IRS ensures that the couple's total ownership is accurately reflected for tax purposes.