Controlled Group Sanity Check

[HTO]

This one seems easy but confirmation is always appreciated.

Company A:

Dad owns 78%

Trust #1 owns 11% (trust is a non-grantor trust for which Dad's adult daughter X is the trustee and sole beneficiary)

Trust #2 owns 11% (same as above but for Dad's adult son Y)

 

Company B:

Dad owns 50%

Trust #3 owns 25% (trust is a non-grantor trust for which X is the trustee and sole beneficiary)

Trust #4 owns 25% (same as above but for Y)

 

Brother-sister controlled group or not?

I think YES, for these reasons:

1. The trust shares are attributed to X and Y (and for the Company A shares, those are attributed to Dad)

2. After attribution:

Company A:

Dad owns 78% (100% by attribution)

X owns 11%

Y owns 11%

 

Company B:

Dad owns 50%

X owns 25%

Y owns 25%

 

Dad, X and Y own more than 80% of both Company A and Company B, and more than 50% of Company A and Company B taking into account identical ownership (50% Dad, 11% X and 11% Y).

Anyone disagree?