Non-profit controlled group rules - common control question

[AndrewZ]

I have a case where a 100% owner of a corporation is a director of a 501(a) nonprofit he founded in an unrelated field. There are 2 other directors of the nonprofit. Let's say he controls the other directors, so he has at least 80% control over the nonprofit (including the appointment/removal of directors).

Is this a controlled group, or does the corporation (as an entity) need to be directly controlling the nonprofit (e.g. the owner's personal decisions over the nonprofits would have to be in his capacity as a representative of corporation - not as a separate individual)? I.e., the "parent-subsidiary" rules apply, not the "brother-sister" rules.

From Reg section 1.414 ( c )-5:

"For this purpose, common control exists between an exempt organization and another organization if at least 80% of the directors or trustees of one organization are either representatives of, or directly or indirectly controlled by, the other organization [does "organization" include the individuals with a controlling interest in that organization, e.g. a 100% owner?]. A trustee or director is treated as a representative of another exempt organization if he or she is also a trustee, director, agent, or employee of the other exempt organization."

Thanks.