Controlled Group-beneficiary of trust as common owner?

[AndrewZ]

For the brother-sister controlled group test, a "common owner" includes a trust. But beneficiaries' interests in the trust (if 5% or more) have to be attributed and treated as the individuals' ownership. Does this mean you would remove all of the attributed ownership from the trust's direct ownership to avoid double-counting? I think this would really only have an impact if an individual had ownership in one company by virtue of attribution from a trust, and also direct ownership in another company, creating common ownership for him/her in both (even though the trust itself isn't a common owner).

This could have the strange result of both the trust (as its own entity) and individuals who are owners by attribution from the trust being in the "5 common owner" determination. Then you would have to remove duplicate ownership from the total and identical ownership counts.

Similarly, if a corporation is an owner of one or more of the companies being tested, the individuals who own 5% or more of that corporation would then be treated as direct owners of the companies it owns.

Does this seem correct?

Thanks.