Controlled Group - Irrevocable Trust

I have a potential client with the following facts:

Person A owns 73.33% 

Person B owns 16.66%

The remaining 10% is owned by a trust. The Trust is an irrevocable trust where Person A is the grantor and Person A's children (ages 25 & 27)  are the beneficiaries. Person A's brother is the trustee of the trust. The children are set to receive 1/3 of the benefit at age 30, 1/2 at age 35 and the rest at age 40.

I am trying to figure out if the children's benefit in the trust should be attributed to Person A, creating a controlled group with a separate company person A owns 100%.

Any help would be greatly appreciated.

Assuming the children's actuarial interests are equal, they each have a 50% interest, well in excess if the 5% threshold. So they are treated as each owning 5% of the company. 1563(e)(3). Because A already owns > 50%, their stock is attributed to A. 1563(e)(6)(B). The second attribution is OK. 1563(f)(2).

But please, pay someone to confirm and get it in writing addressed to client, because this stuff gets messed up all the time and I only spent 5 minutes to come up with what I think is answer. Kick the tires.