Rev. Rul. 68-587

The taxpayer, a United States person as defined in section 4920(a)(4) of the Internal Revenue Code of 1954, was compensated for services rendered to a foreign person by a transfer of ownership of stock of a foreign corporation. Held, the receipt of the stock by the taxpayer in payment for services is an acquisition of stock of a foreign issuer within the meaning of section 4912 of the Code and as such it is subject to the interest equalization tax imposed by section 4911(a) of the Code unless the transaction is excluded or exempted from such tax by another provision of the Code.