Vlad401k Posted March 8, 2018 Share Posted March 8, 2018 Let's say husband and wife own 50% each of Company A. They also have some ownership in other companies, which could form a potential Brother-Sister Controlled Group. Would you consider them both as 100% owners when determining the if the controlled group relationship exists for a Brother-Sister Controlled Group, because of attribution, or would they just be considered 50% owners? Thanks. Link to comment Share on other sites More sharing options...
Belgarath Posted March 8, 2018 Share Posted March 8, 2018 100% Link to comment Share on other sites More sharing options...
Vlad401k Posted March 8, 2018 Author Share Posted March 8, 2018 Ok, so basically when you're creating the brother-sister table to determine if you pass the 80% test for total common owners and 50% test for identical ownership, what would those percentage be for Company A? I assume that both the total for common owners would be 100% and the identical ownership would also be 100%. Would you agree? Link to comment Share on other sites More sharing options...
Larry Starr Posted March 8, 2018 Share Posted March 8, 2018 You treat the two of them as one person with an ownership equal to the total they own together. Use that "individual" in your ownership table for testing. Company A is owned 100% by the "individual" Mr/Mrs. Does that help? Lawrence C. Starr, FLMI, CLU, CEBS, CPC, ChFC, EA, ATA, QPFC President Qualified Plan Consultants, Inc. 46 Daggett Drive West Springfield, MA 01089 413-736-2066 larrystarr@qpc-inc.com Link to comment Share on other sites More sharing options...
Vlad401k Posted March 8, 2018 Author Share Posted March 8, 2018 Yes! Thank you. Link to comment Share on other sites More sharing options...
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