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Guest Tara Curran
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We have a client who is an LLC owned by 2 entities. One of these entities (Entity A) is owned by approximately 10 individuals and 5 or fewer individuals do not own 80% of this entity. In determining if the LLC is part of a controlled group with another corporation, do we consider that Entity a is not owned by at least 5 or fewer persons so the LLC is not part of a controlled group since they fail the 80% test? Or do we only consider that the LLC is owned over 80% by only 2 corporations? In other words, do we look through the entities and compare the indivudal ownership and deem that they own the LLC?

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