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(2 Persons are under common control if they are members of a "controlled group of corporations", as defined in regulations prescribed under section 414(b) of the Code, or if they are "two or more trades or businesses under common control", as defined in regulations prescribed under section 414(c) of the Code.
Section 1563(a)(2) provides that a "controlled group of corporations" includes a "brother-sister controlled group," defined as "two or more corporations if 5 or fewer persons..
1 Section 1563(a)(2) provides that a "controlled group of corporations" includes a "brother-sister controlled group," defined as "two or more corporations if 5 or fewer persons..
(ii) a member of a controlled group of corporations which includes such employer.
The term "electing group" means a controlled group of which one or more members is an electing corporation.
(ii) any member of a controlled group of corporations (within the meaning of section 409(l)(4)) of which the employer described in clause (i) is a member.
Similar(43)
L. 91 172 substituted reference to component members of a controlled group for reference to members of an affiliated group in pars.
(1) In connection with any person, a controlled group consists of that person and all other persons under common control with such person.
The Commissioner would find the 80-percent requirement met as well, and would therefore define all five corporations as part of a controlled group, because various subgroups of the five or fewer shareholders can account for 80percentt of each corporation.
For purposes of the requirements of paragraphs (2) and (3), all certified professional employer organizations that are members of a controlled group within the meaning of sections 414(b) and (c) shall be treated as a single organization.
Keep practicing the song and smiling until you never want to hear it again, until you know it so well that you could just randomly start singing it in the middle of a large controlled group of kids (in a rehearsal or such) without a doubt in your ability to sing the song without any mistakes, and until you can sing it at a range of tempos.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com