Rev. Rul. 68-612

The taxpayer, a United States person as defined in section 4920(a)(4) of the Internal Revenue Code of 1954, acquired stock of a foreign issuer from X , a foreign person. The person from whom X acquired the stock was a United States person. If the taxpayer had acquired the stock from the United States person, such acquisition would not have been subject to the interest equalization tax because of the exemption for prior American ownership and compliance provided by section 4918(a) of the Code.

Held, the acquisition by the taxpayer of the stock of a foreign issuer in the instant case is not exempt from the interest equalization tax for prior American ownership and compliance provided by section 4918(a) of the Code since such exemption does not apply in any case where a United States person acquires stock of a foreign issuer from a foreign person.