more than 50 percent
(5)The term “controlled group of corporations” has the same meaning given to such term by section 1563(a), except that— (A)“more than 50 percent” shall be substituted for “at least 80 percent” each place it appears in section 1563(a)(1), and (B)the determination shall be made without regard to subsections (a)(4) and (e)(3)(C) of section 1563.