Controlled Group/For Profit/Non-Profit

[austin3515]

5 people own 20% of a business. The same 5 people make up the board of a non-profit. Controlled Group?

[rcline46]

It would appear that they do not control the for profit at 20% ownership, and so no controlled group.

[mphs77]

Did you mean 5 people each own 20% of a business?

[jpod]

I assume Austin was saying that each of those five people owns 20% of the for-profit entity. Austin, you need to work your way through the 1.414©-5 regulation (assuming the non-profit is a tax-exempt entity, rather than a taxable non-profit). Unless there is common control via that regulation, I don't see how you would have a 414 affiliation.

[austin3515]

Yes, 20% each. Anyone care to comment? That is the extent of the relationship.