1563 Attribution & Spousal Exception

[Dennis Povloski]

Wasn't sure where to post this one, so started in this forum....

The 1563 attribution rules have an exception for spousal attribution if certain conditions are met.

Husband owns 100% of his own business

Wife owns 60% of her family business (her siblings are the other two owners)

Husband works in and manages the wife's family business. He is deemed to own her shares for sure.

The wife has nothing to do with the husband's business, and her business is completely separate from the his business (no common customers, products, services, no income going back and forth, etc.).

Is the wife deemed to own shares in the husband's business?

I'm not sure if attribution exception is blown for one spouse, if that means it's also blown for the other spouse...

Thanks!