Controlled group of corporations.

(2) Controlled group of corporations. For purposes of this paragraph, the term controlled group of corporations has the same meaning assigned to the term in section 1563(a) and not section 993(a)(3) and 1.993-1(k). Thus, for purposes of this paragraph, the test of control is 80 percent control and, since the rules of section 1563(b) apply, only domestic members are considered to be members of the controlled group.

Source

26 CFR § 1.993-5


Scoping language

None
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