(a) WagesFor purposes of this subpart—
(2) Certain training and educational benefits
(A) In generalThe following amounts shall be treated as wages paid to an employee:
(B) Related person
A person is related to any other person if the person bears a relationship to such other person specified in section 267(b) or 707(b)(1), or such person and such other person are engaged in trades or businesses under common control (within the meaning of subsections (a) and (b) of section 52). For purposes of the preceding sentence, in applying section 267(b) or 707(b)(1), “10 percent” shall be substituted for “50 percent”.
(b) Controlled groupsFor purposes of this subpart—
(1)
all employers treated as a single employer under subsection (a) or (b) of section 52 shall be treated as a single employer for purposes of this subpart, and
(2)
the credit (if any) determined under section 1396 with respect to each such employer shall be its proportionate share of the wages giving rise to such credit.