Control Group Determination

[pixmax]

Company A Company B

Owner A 99 % Owner A 69%

Owner B 1% Owner B 1%

Owner C 30%

Owner A and C are cousins. Owner A does not receive income or from Company B and Owner C does not receive income from Company A.

I believe it's controlled based on 50% identical ownership correct?

[rcline46]

CG for accounting yes, CG for pensions no, ASG undetermined

[Tom Poje]

if it helps, see the example on 7.7 of the IRS controlled group guideline

all you need do is change the percentages to match what you have.

as noted above, undetermined if affiliated service group exists

irs controlled group notes.pdf

[austin3515]

If you subscribe to TAG they have sweet template that will analyze up to 5 entities (maybe 4?) for 4 owners. Just put in your data and there are these really cool formulas that say "Company 1 and Company 2 are a controlled group" or Company 3 and 4 are a controlled group and Companies 1 and 5 are a controlled group.

I'd share it but I would feel bad publishing their intellectual capital.

[Calavera]

CG for accounting yes, CG for pensions no, ASG undetermined

I agree that it is not a CG for pensions. I don't know what is the difference between pension and accounting. Can you explain why it is a CG for accounting?

[rcline46]

If you look at the code, it was modified several years ago from 80% to 50%. Then the pension only 80% was added back in a later sub-section.

[My 2 cents]

Original post indicates that A and C are cousins. What difference would that make? Cousins don't count for family aggregation, do they?