Determination of Controlled Group

[pixmax]

Need to determine if I have a control group and if possible to change the ownership around so that they are not controlled.

The children are all over 18 and do not work for any of the companies. Those controlling 1% ownership are also not employees.

Dad A and B are brothers.

Any help would be greatly appreciated.

Control group.xlsx

[Lou S.]

This may be helpful

http://www.irs.gov/pub/irs-tege/epchd704.pdf

I think that Company C & D are controlled by virtue of Child #4 ownership being attributed to Dad B.

I do not think any of the others are controlled assuming all the children over 18 are also over age 21 which I believe is the age for 1563.

[pixmax]

Thanks for your reply. All children are over age 21. If company D changed child 4 to 40% and gave child 1,2 and 3 5% ownership would this then not be controlled since child D is now under the 50%?

[Calavera]

I think that Company C & D are controlled by virtue of Child #4 ownership being attributed to Dad B.

I don't think so. It is Dad B's ownership that is attributed to Child #4. Since all children are over age 21, and each has ownership in only one company, they all should be ignored. Therefore, I believe there are no control groups in this example.

[Lou S.]

I think that Company C & D are controlled by virtue of Child #4 ownership being attributed to Dad B.

I don't think so. It is Dad B's ownership that is attributed to Child #4. Since all children are over age 21, and each has ownership in only one company, they all should be ignored. Therefore, I believe there are no control groups in this example.

You're correct. I had my attribution direction crossed up. It attributes to the person with greater than 50% of the business but not the other way. Thanks for picking that up.