ATTRIBUTION RULES APPLICABLE TO STOCK OWNERSHIP.

SEC. 1253. ATTRIBUTION RULES APPLICABLE TO STOCK OWNERSHIP. Section 856(d)(5) (relating to constructive ownership of stock) is amended by striking “except that” and all that follows and inserting “except that— “(A) ‘10 percent’ shall be substituted for ‘50 percent’ in subparagraph (C) of paragraphs (2) and (3) of section 318(a), and “(B) section 318(a)(3)(A) shall be applied in the case of a partnership by taking into account only partners who own (directly or indirectly) 25 percent or more of the capital interest, or the profits interest, in the partnership.”.