Two LLC's are owned as follows by W, X, Y, and Z (all unrelated adults). Are they a brother-sister controlled group?
Since Y and Z have no interest in LLC-B, it wd appear that the more than 50% rule is not met and they are not controlled under Section 1563. Does anyone agree or disagree?
Individuals.....................LLC-A.................LLC-B
W .......................................25%.................. 50%
X .......................................25%.................. 50%
Y .......................................25%
Z .......................................25%