Controlled group - attribution of stock owned by trust to individual b

[Guest Mary Mlock]

We are trying to determine if two corporations are members of a controled group. Both corporations are owned by individual shareholders and by trusts. Some of the trust beneficiaries are the same as the individual shareholders of the corporations. How do you calculate the actuarial interest of the beneficiary in the trust in order to determine the interst attributed to that individual in order to determine if the companies are members of a controlled group? The individual shareholders are for the most part income beneficiaries in the trusts and the remaindermen are the adult children of these individuals.