Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 58-14

1958-1 C.B. 358

Full Text

Rev. Rul. 58-14

A partnership, although the sole owner of one or more foreign corporations, does not qualify for the election provided by section 3121(1) of the Federal Insurance Contributions Act (chapter 21, subtitle C, Internal Revenue Code of 1954). This section provides that a domestic corporation may, under certain specified conditions, elect to have the insurance system established by title II of the Social Security Act extended to certain employees of any one or more of its foreign subsidiaries. The term `corporation' as used in section 3121(1) of the Code includes associations, joint stock companies, and insurance companies, but does not include partnerships.