Controlled Group Determination Help !

[12AX7]

Testing is getting to the better of me, and I can sure use a little help with this Controlled Group Determination. For this example, assume that the non-involvement exception does not apply between the Wife (of Grand Dad) and Grand Dad for purposes of stock attribution. I hope I've provided enough facts and the family references are not confusing. I appreciate the assistance.

Company A Company B Company C

Company A 60 0 N/A

Son (of Grand Dad) 40 50 22.97

Wife (of Grand Dad) 0 50 0

Grand Dad 0 0 41.84

Daugther (of Grand Dad) 0 0 15.87

Daugther (of Son) 0 0 4.83

Son (of Son) 0 0 4.83

Grand Child (of Grand Dad)0 0 4.83

Grand Child (of Grand Dad)0 0 4.83

Edit - after posting this, I can see that this is not lining up in a grid as I composed this. How do I get this lined up to make it easier to read? HELP !

[ETA Consulting LLC]

Identify each company with it's direct owners and their ownership percentages. Company As owners are? Company Bs owners are? Company Cs owners are?

Next, how is each individual related?

That should get you started. Don't use a grid.

Good Luck!

[12AX7]

Ok, let's try again at how the ownership breaks down:

Company A:

Company C - 60%

B - 40%

Company B:

B - 50%

G (mother of B) - 50%

Company C:

B - 22.97%

M (father of B) - 41.84%

J (daugher of M) - 15.87%

K (daugher of B) - 4.83%

R (son of B) - 4.83%

Je (daugher of J) - 4.83%

Ja (son of J) - 4.83

Again, we are assuming that the non-involvement exception does not apply between M and G (currently married). Thanks again for the help.

[ETA Consulting LLC]

This is your start. Your next approach (and it requires a strong attention to detail as it's like putting together a jigsaw puzzle) is to print off Section 1563 of the code and begin to identify your attribution points. For instance, you know there "shouldn't" be attribution between individuals B and G on company B since they are mother and son while neither owns "MORE THAN" 50% of the company.

You also know that if any individual owns "AT LEAST" 5% of a coporation, then they are attributed ownership of what that corporation owns. So, the 60% of Company A should be attributed down to individuals in Company C (because a few owns at least 5%).

You also have to keep an eye on "Spousal Attribution". It's not automatic, but there are some instances where the ownership of individuals M and G "MAY BE" attributed to each other. It could be the result of the level of passive income.

You have the correct layout, you'd have to being plugging in the lines from here.

Good Luck!