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Showing results for tags 'Doesnt seem right.'.
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Husband and wife each have 50% ownership in their own companies. The other 50% of her company is owned by a friend and the other 50% of his company is owned by his brother. Due to the couple's minor children, they can't rely on the spousal exception. So, the 80% test is satisfied because it looks like husband and wife own a total of 100% of each company. But the identical ownership (50%) test also adds up to 100%. I feel like there's double attribution going on here -- or maybe the fact that neither has effective control (voting power) in the other's company that makes me think that the 50% test is not met. Is my intuition steering me in the right direction, or am I grasping at straws and just need to face facts?