72
Ante, pp. 64, 67, 69.
i<inte, p. 71.
PUBLIC LAW 88-272-FEB. 26, 1964
[78 STAT.
"(2) JoiXT TENAXCY.—The acquisition of a share of stock in the name of the employee and another jointly with the right of survivorship or a subsequent transfer of a share of stock into such joint ownership shall not be deemed a disposition, but a termination of such joint tenancy (except to the extent such employee acquires ownership of such stock) shall be treated as a disposition by him occurring at the time such joint tenancy is terminated. " (d) ATTRIBUTION OF STOCK OWNERSHIP.—For purposes of this part, in applying the percentage limitations of sections 4 2 2 (b)(7), 423(b)(3), and424(b)(3)— "(1) the individual with respect to whom such limitation is being determined shall be considered as owning the stock owned, directly or indirectly, by or for his brothers and sisters (whether by the whole or half blood), spouse, ancestors, and lineal descendants; and "(2) stock owned, directly or indirectly, by or for a corporation, partnership, estate, or trust, shall be considered as beingowned proportionately by or for its shareholders, partners, or beneficiaries. "(e) PARENT CORPORATION,—For purposes of this part, the term 'parent corporation' means any corporation (other than the employer corporation) in an unbroken chain of corporations ending with the employer corporation if, at the time of the granting of the option, each of the corporations other than the employer corporation owns stock possessing 50 percent or more of the total combined voting power of all classes of stock in one of the other corporations in such chain. " (f) SUBSIDIARY CORPORATION.—For purposes of this part, the term 'subsidiary corporation' means any corporation (other than the employer corporation) in an unbroken chain of corporations beginning with the employer corporation if, at the time of the granting of the option, each of the corporations other than the last corporation in the unbroken chain owns stock possessing 50 percent or more of the total combined voting power of all classes of stock in one of the other corporations in such chain. " (g) SPECIAL RULE FOR APPLYING SUBSECTIONS (e) AND (f).—In applying subsections (e) and (f) for purposes of section 422(a)(2), 423(a)(2), and 424(a)(2), there shall be substituted for the term 'employer corporation' wherever it appears in subsections (e) and (f) the term 'grantor corporation', or the term 'corporation issuing or assuming a stock option in a transaction to which section 425(a) applies', as the case may be. "(h)
MODIFICATION, EXTENSION, OR RENEWAL OF OPITON.—
"(1) IN GENERAL.—For purposes of this part, if the terms of any option to purcliase stock are modified, extended, or renewed, such modification, extension, or renewal shall be considered as the granting of a new option. "(2)
SPECIAL RULES FOR SECTIONS 4 2.{ AND 4 24 O P I TO N s. —
" (A) I n the case of the transfer of stock pursuant to the exercise of an option to which section 423 or 424 applies and which has been so modified, extended, or renewed, then, except as provided in subparagraph (B), the fair market value of such stock at the time of the granting of such option shall be considered as whichever of the following is the highest: " (i) the fair market value of such stock on the date of the original granting of the option, " (ii) the fair market value of such stock on the date of the making of such modification, extension, or renewal, or
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