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MGKS
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Question 16: The principal business of A is performing, on a regular and continuous basis, management functions for B and C. B is not related (as used in 414(m)(5)) to A or C, but C is a wholly owned subsidiary of A. A does not have any other significant source of revenue, and does more work for (and receives more income from) B than it does from C. Are A and C members of a "management" affiliated service group under 414(m)(5)? |
Answer: No, but A and C are a parent-subsidiary controlled group under 414(b), or a group of trades or businesses under common control under 414(c). If you are dealing with a wholly owned entity, that is the case. |
Answers are provided as general guidance on the subjects covered in the question and are not provided as legal advice to the questioner or to readers. Any legal issues should be reviewed by your legal counsel to apply the law to the particular facts of this and similar situations.
The law in this area changes frequently. Answers are believed to be correct as of the posting dates shown. The completeness or accuracy of a particular answer may be affected by changes in the law (statutes, regulations, rulings, court decisions, etc.) that occur after the date on which a particular Q&A is posted.
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