substantial owner

substantial owner
USA
An individual who, at any time during the 60-month period ending on the date that the determination is made, satisfies one of three conditions:
• Owns the entire interest in an unincorporated trade or business.
• In the case of a partnership, is a partner who owns, directly or indirectly, more than 10% of either the capital interest or the profits interest in the partnership.
• In the case of a corporation, owns, directly or indirectly, more than 10% in value of:
1. the voting stock of the corporation; or
2. all the stock of the corporation.
For purposes of determining ownership interests in a corporation, the constructive ownership rules of IRC § 1563(e) apply (other than the rules in paragraph 1563(e)(3)(C)), including the application of the rules under IRC § 414(c).

Practical Law Dictionary. Glossary of UK, US and international legal terms. . 2010.

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