Related person.

Related person. For purposes of this section, persons are considered to be related if -
(1) They are partners or partnerships described in section 707(b)(1) of the Code; or
(2) They are related within the meaning of section 267 (b), (c), and (f) of the Code, except that -
(1) They are partners or partnerships described in section 707(b)(1) of the Code; or
(2) They are related within the meaning of section 267 (b), (c), and (f) of the Code, except that -
(i) “10 percent or more” shall be substituted for “more than 50 percent” each place it appears; and
(ii) Section 1563 shall apply (for purposes of section 267(d)), without regard to section 1563(b)(2).
(i) Effective date. Except as specifically provided to the contrary elsewhere in this section, this section applies to transfers occurring after December 31, 1984.

Source

26 CFR § 1.367(d)-1T


Scoping language

None
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