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Posted

I need to confirm that the rules of attribution does not apply to this scenario:  Dad and Mom own two companies that are considered brother-sister controlled group, they are planning to sell XYZ to son A and B (age 21 or older), and the sons are planning to split the company and create two separate corporations.  I looked into the control group/rules of attribution and it seems they are no longer considered a control group and the rule of attribution does not apply because the parent does not own greater than 50% of son's businesses.   Any takers?

 

 

                  ABC    XYZ  

Mom           50%    50%

Dad             50%    50%

 

           XYZ becomes LOL    DBA

Son A                         100%

Son B                                    100%

Posted

I haven't had to look at this in a while, but the rules vary some depending on which part of the Tax Code is in play.

In other words be careful, because what may be OK in one scenario may not be OK in another scenario.

Posted

I haven't had to look at this in a while, but the rules vary some depending on which part of the Tax Code is in play.

In other words be careful, because what may be OK in one scenario may not be OK in another scenario.

 

Exactly, that is why I am trying to get feedback from others, this one is not a simple yes or no question.

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