Controlled Group Question

[AJ North]

We have a rather complex controlled group situation. There are over a half dozen companies, two grandparents (primary owners), 11 children and 6 grand children, plus other unrealted individuals owning stock in these companies.

This may be a dumb question, but with a group this big, would the five or fewer rule have an impact on a controlled group analysis? In many cases, there are more than 5 individuals that own stock.

Thank you.

[ETA Consulting LLC]

Sure, especially when you consider the stock attribution rules. You'd actually have to perform the analysis in order to make the determination.

Good Luck!

[austin3515]

It depends. The determination is made AFTER attribution. So if the two grandparents, after attribution own 100% of the entities together (50/50), then only two people are in the analysis.

Based on what you've told us, there probably won't be a lot of attribution under 1563 (for controlled groups) but you still need to go through the excercise.

Step is to go through each individual independently and figure out how much that person owns of each individual entity after attribution.

Good luck.

[AJ North]

Thank you all for your input. You have confirmed my thoughts. I will really need luck here, I am dealing with 18 family members, 6 non-family members and 6 different companies.