Attribution

From Wikicpa

Under certain circumstances, the tax law applies attribution rules to assign to one taxpayer the ownership interest of another taxpayer.

If for example, the stock of "Sample" corporation is held 75% by A and 25% by B, A may be deemed to own 100% of the Sample corporation stock if A & B are father and son. In such a case, the stock ownership by B is attributed to A. In other words, A has 75% "direct" ownership and B has 25% "indirect" ownership.