Over the past three months, we’ve taken a deep dive into one of the most misunderstood—and potentially dangerous—areas of the tax code: the attribution rules under Sections 267, 318, and 1563.

These rules can quietly turn a routine transaction into a denied loss deduction, unexpected stock ownership, or even a controlled group problem. Family relationships, entity structures, and stock options can trigger constructive ownership in ways that surprise even seasoned business owners and tax professionals.

To make this complex topic easier to navigate, we’ve created a concise, side-by-side comparison of the three major attribution regimes, highlighting

which family members are included (and which are not),

when sibling attribution applies,

how entity-to-individual and individual-to-entity attribution works,

the percentage thresholds, and

the primary purpose behind each code section.

This handy reference guide is designed to live on your desktop—so when an attribution question arises, you’ll have clarity in seconds.

If you advise business owners, operate multiple entities, or engage in transactions with family members, this is a resource you’ll want at your fingertips.

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