Internal Revenue Code · 26 U.S.C.
§ 269B. Stapled entities
Official text, no changes From the Office of the Law Revision Counsel, release point 119-121 (current through Public Law 119-121 (October 9, 2026)). Compare it with the official text at uscode.house.gov (external site).
Cite as 26 U.S.C. § 269B
At a glance
Read from the text, the source credit and the official notes. Not part of the law.
- Status
- In force
- Added
- July 18, 1984 by Pub. L. 98–369
- Last amended
- October 22, 1986 by Pub. L. 99–514
- Amendments
- 1 dated changes in the source credit
- Length
- 5 subsections · 524 words · about 2 min to read
- Defines
- 2 terms
- Cross-references
- cites 5; cited by 0 Code sections and 7 other regulations
- Regulations
- 2 issued under this section
The Secretary shall prescribe such regulations as may be necessary to prevent avoidance or evasion of Federal income tax through the use of stapled entities. Such regulations may include (but shall not be limited to) regulations providing the extent to which 1 of such entities shall be treated as owning the other entity (to the extent of the stapled interest) and regulations providing that any tax imposed on the foreign corporation referred to in subsection (a)(1) may, if not paid by such corporation, be collected from the domestic corporation referred to in such subsection or the shareholders of such foreign corporation.
The term “entity” means any corporation, partnership, trust, association, estate, or other form of carrying on a business or activity.
The term “stapled entities” means any group of 2 or more entities if more than 50 percent in value of the beneficial ownership in each of such entities consists of stapled interests.
Two or more interests are stapled interests if, by reason of form of ownership, restrictions on transfer, or other terms or conditions, in connection with the transfer of 1 of such interests the other such interests are also transferred or required to be transferred.
Nothing in section 894 or 7852(d) or in any other provision of law shall be construed as permitting an exemption, by reason of any treaty obligation of the United States heretofore or hereafter entered into, from the provisions of this section.
(Added Pub. L. 98–369, div. A, title I, § 136(a), July 18, 1984, 98 Stat. 669; amended Pub. L. 99–514, title XVIII, § 1810(j), Oct. 22, 1986, 100 Stat. 2829.)
Terms defined here
Where the text says “the term … means”. Select a term to jump to its definition.
Regulations under this section
Treasury regulations (26 CFR) issued under § 269B
Cross-references
Computed from the citations in the text of Title 26 and 26 CFR.
This section cites 5 other sections
- § 1563 Definitions and special rules
- § 894 Income affected by treaty
- § 958(a) Rules for determining stock ownership
- § 318(a) Constructive ownership of stock
- § 7701(a)(30) Definitions
Cited in 7 regulations not issued under it
- § 1.367(b)-2 Definitions and special rules.
- § 1.884-1 Branch profits tax.
- § 1.884-4 Branch-level interest tax.
- § 1.1297-1 Definition of passive foreign investment company.
- § 1.1503(d)-1 Definitions, special rules, and filings.
- § 1.1502-77B Agent for the group applicable for consolidated return years beginning on or after June 28, 2002, and before April 1, 2015.
- § 301.9100-6T Time and manner of making certain elections under the Deficit Reduction Act of 1984.
Amendment history
From the source credit and the official notes, newest first.
Where it sits in the Code
- Subtitle A Income Taxes
- Chapter 1 NORMAL TAXES AND SURTAXES
- Subchapter B Computation of Taxable Income
- Part IX ITEMS NOT DEDUCTIBLE
Nearby sections
- § 267A Certain related party amounts paid or accrued in hybrid transactions or with hybrid entities
- § 268 Sale of land with unharvested crop
- § 269 Acquisitions made to evade or avoid income tax
- § 269A Personal service corporations formed or availed of to avoid or evade income tax
- § 269B Stapled entities
- § 270 Repealed
- § 271 Debts owed by political parties, etc.
- § 272 Disposal of coal or domestic iron ore
- § 273 Holders of life or terminable interest
Official notes
The Law Revision Counsel's notes for this section (amendments, effective dates and related laws) are long, so they have their own page.