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Showing results for tags 'controlled'.
Found 4 results
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I appreciated you articles and was wondering if you can help me understand irs rules re ownership vs voting control. I have a question about controlled groups for 2 corporation 1 SCorp individual A owns 100% , individual A also owns 49% of a c-Corp but has a retained proxy voting rights for an additional 5% of the c-Corp (so he has voting proxy for 54%) would both companies be a controlled group for 401k and DB plan purposes.
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I have a situation where Husband owns 100% of one business and Wife owns 100% of an unrelated business. They are considering setting up a defined benefits plan for their businesses. Operation of both businesses is kept completely separate and neither has any involvement in the others business. Further, neither is an employee or officer of the others business. They reside in Texas, a community property state. However, they have a post-nuptial agreement which provides that neither has ownership in the others business and that income from the businesses are also separate property so there appears to be no direct ownership issues. So long as the property is characterized as separate property, would the exception for aggregation under the control group rules for an independent spousal business apply? -
I have a client with 3 seperate companies. I won't get into the weeds but here are the facts: Company A is FSO with Company C as the A-Org Company B is FSO with Company C as the A-Org Company A & B are not related through ownership, however employees for both A & B do the billing for A & B making them B-Orgs for eachother My question is, since A if affiliated with C (A-Org), B is affiliated with C (A-Org) and A is affiliated with B (B-Org), Are all three related or... Should A be tested with C, B tested with C, and A tested with B? Is it possible to combine all three for testing?
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Do the family attribution rules (for controlled group purposes) apply between a family member residing outisde the United States who is not an American citizen and a family member residing in the United States?
