Two 415 limits and Stock Attribution

[John Feldt ERPA CPC QPA]

A father owns 100% of his corporation A, and he employs his 3 kids there now (all over age 21). He plans to start another corporation with his 3 kids - Corporation B. The kids will own none of Corp. A, but will each own 17% of Corp. B, with their father owning the rest of Corp. B. The father and the kids will work for both Corps, receiving compensation from both.

I think the father does not have two 415 limits due to having direct ownership in both corps, but what about the kids? Do the attribution rules also prevent them from having two 415 limits?

[John Feldt ERPA CPC QPA]

I must change my mind regarding the father, since the corps. are not a controlled group, then I believe he can also have two 415 limits.

But if the father lowers his ownership in Corp. A by a percent or more and it's bought by one of his kids, then it becomes a controlled group (I think), then the cool two 415 limit thingy goes away and becomes one 415 limit?

("cool" and "thingy" are just technical terms, don't worry about those)

[ak2ary]

If the father owns 51% or more of corp. B, the kids stock will attribute to Dad and there will be a controlled group. If the kids own at least 1% of Company A there will be a controlled group. Once there is a controlled group, there is 1 415 limit applicable to each employee, stockholder or not