Spencer Posted December 6, 2012 Posted December 6, 2012 I work alone and I'd just like a second opinion (or more) on this. Is there a brother-sister controlled group in this situation? Son (over 21) owns 100% of Company A and 49% of Company B. Father owns zero percent of COmpany A and 49% of Company B. Other 2% of Company B owned by unrelated individuals. Thanks!
ETA Consulting LLC Posted December 6, 2012 Posted December 6, 2012 Doesn't appear to be one. There is no attribution between son and father since neither owns "more than 50%" of the company. You should be sure to account for the affiliated service group analysis as well. Good Luck! CPC, QPA, QKA, TGPC, ERPA
four01kman Posted December 6, 2012 Posted December 6, 2012 Something sticks in my mind that father and son are deemed to own the other's position (IRC 1563 maybe). If so, there would be a controlled group. Jim Geld
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