CONTROLLED GROUPS
01.Core Concepts
• A controlled group consists of two or more commonly owned corporations. • The controlled group rules are intended to prevent potential abuses by taxpayers. • Controlled groups are treated as a single entity for testing and limits. • Aggregation is required when: • one entity owns at least 80 percent of another entity, or • the same five or fewer owners own at least 80 percent of both entities and more than 50 percent of each entity is held by owners with identical holdings in the other entity. • Constructive ownership applies based on family attribution.