Controlled Group Rules - Attribution to IRA Owner?

I'm trying to determine whether stock held by an IRA is attributable to the owner for purposes of the controlled group rules.  So, for example, if I own 100% of Company A, and my IRA owns 100% of Company B, am I deemed to own 100% of Company B, such that A and B are in a brother/sister controlled group?

I know the answer is "yes" in the context of a qualified plan (based upon the language in 414(b) stating that 1563(e)(3)(C) doesn't apply).  However, I have not been able to find a discussion of the application of these rules to IRAs anywhere.  From a policy standpoint, the case for attribution would seem to be even more compelling in the IRA context, given that there's always going to be a single individual who owns the entire account.

I find it hard to believe that this issue hasn't been addressed, and I assume I'm missing something obvious.   

Without doing the whole analysis for your questions:

Subparagraph 1563(e)(3)(C) excuses from paragraph 1563(e)(3) only “stock owned by any employees’ trust described in section 401(a) which is exempt from tax under section 501(a).”

If one looks only at that tiny bit of the Internal Revenue Code, might one infer that stock owned by something that is not a § 401(a) plan’s trust does not get § 1563(e)(3)(C)’s excuse, leaving § 1563(e)(3)(A)-(B) to apply as they otherwise might apply?

http://uscode.house.gov/view.xhtml?req=(title:26%20section:1563%20edition:prelim)%20OR%20(granuleid:USC-prelim-title26-section1563)&f=treesort&edition=prelim&num=0&jumpTo=true

Thank you for the response, Peter.  I had that same thought.  If 1563(e)(3)(A)-(B) apply, then presumably, the ownership would be attributed to the IRA holder, at least provided that the IRA is structured as a trust account.  However, what if the IRA is structured as a custodial account pursuant to 408(h)?  Would that lead to a different result under 1563(e)(3)(A)-(B)?  It certainly doesn't seem that it should from a policy standpoint.  

Again - I'm just surprised that I haven't found a more robust discussion of this topic anywhere, and I'm probably missing something.

A sensible way to interpret § 1563(e)(3)’s reference to a trust might be to recognize that an IRA custodial account is a trust substitute.

Internal Revenue Code § 401(f) treats a bank’s or trust company’s custodial account as a qualified trust if “the custodial account or contract would, except for the fact that it is not a trust, constitute a qualified trust under [§ 401][.]”

Likewise, § 408(h) treats a bank’s or trust company’s IRA custodial account as an IRA trust.

http://uscode.house.gov/view.xhtml?req=(title:26%20section:408%20edition:prelim)%20OR%20(granuleid:USC-prelim-title26-section408)&f=treesort&edition=prelim&num=0&jumpTo=true

23 minutes ago, Peter Gulia said:

Likewise, § 408(h) treats a bank’s or trust company’s IRA custodial account as an IRA trust.

Thanks again, Peter.  I like that conclusion.  I was hung up on the language at the outset of 408(h) which provides that it applies "for purposes of this section."  However, there is also the last sentence that says the custodian will be treated as the trustee (which implies, at least to me, that the custodial account will be treated as a trust) "for purposes of this title," which would include 1563.

I'm inclined to go with this analysis unless anyone else has other thoughts on this that they would be kind enough to share. 

Thank you again, Peter, for all of your help!