Another am I controlled group question

Hi

I am 79% owner of a c-corp, other 21% owned by my siblings

I am also a 100% owner of an LLC

I am not a CG, correct? It is not relevant how the LLC is taxed.

No ASG issues.

Thanks

Probably not a CG. But remember, even though there is no family attribution from siblings, there could be, for example, certain options to purchase some or all of the other 21%, that would count as "ownership" for these purposes. Most CG determinations frankly don't seem to take into account such intricacies, which is why we always advise clients to seek legal/tax counsel before making the determination. Or at least do a deeper dive into the rules.

P.S. I just read another post of yours where Cuse makes the exact same point with regard to options.

Hi

Always aware of the options and always let the clients know.

Thank you for your comments.

6 hours ago, Belgarath said:

even though there is no family attribution from siblings

You don't know how hard it is to resist ......