controlled group question

[Santo Gold]

This is straightforward but my conclusion does not seem to make logical sense:

Husband and wife each own 50% of Company A

Husband and wife each own 22.50% of Company B.  Other non-related businesses/individuals own the other 55%.

Under attribution rules, each spouse owns 45.00% of Company B.  That makes identical ownership between them 90% of Company B.  Since their common ownership of Company A is 100%, then there is a CG between A and B.

Does that sound correct?  They really only own 45% of Company B and it would not seem to be logical that that there would be a CG with them really only owing 45% of Company B

Any comments are appreciated.

 

[Bri]

Yeah, it's not 45 MORE percent that they own from each other....

[Santo Gold]

Quote

 

Thank you Bri.  Could you explain further as I am not sure if you are agreeing that for identical ownership combined they are 90% or 45%?

 

[justanotheradmin]

Conceptually, think of the H/W as one person. Don't treat them as two separate individuals. 

New Combined Person owns 100% of Company A, and New Combined Person also owns 45% of Company B. 
Identical ownership is only 45%

[Bri]

The identical ownership is 45, and the 45% they are deemed to co-own is identical, the same 45% of the company.