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Controlled Group - Attribution


Vlad401k

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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.

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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?

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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

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