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Controlled Group Question


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Guest chris4013
Posted

Is this a Controlled Group?

Joe Smith owns 100% of company A.

Company A owns 75% of Company B

Joe Smiths kid age 23 owns 10% of Company B

Joe Smiths brother owns 15% of Company B.

Guest chris4013
Posted

Can you elaborate? I don't see it. In my mind under 1563 since the kids don't own more than 50% of stock there is no attribution. So what are you looking at to make your determination?

Posted

Joe Smith owns 100% of Co. A

Co. A owns 75% of Co. B. Thus through attribution Joe Smith owns 75% of Co. B

Joe Smith's adult son owns 10% of Co. B. That ownership is also attributed Joe Smith since he is deemed to already own 75% of Co. B through other attribution.

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