| (i) P Corporation owns stock possessing 51 percent
of the total combined voting power of all classes of stock entitled
to vote of S Corporation. P is the common parent of a parent-subsidiary
controlled group consisting of member corporations P and S.
(ii) Assume the same facts as in clause (i) of this
subparagraph. Assume further that S owns stock possessing 51 percent
of the total value of shares of all classes of stock of X Corporation.
P is the common parent of a parent-subsidiary controlled group consisting
of member corporations P, S, and X. The result would be the same if
P, rather than S, owned the X stock.
(iii) P Corporation owns 51 percent of the only class
of stock of S Corporation and S, in turn, owns 30 percent of the only
class of stock of X Corporation. P also owns 51 percent of the only
class of stock of Y Corporation and Y, in turn, owns 30 percent of
the only class of stock of X. P is the common parent of a parent-subsidiary
controlled group consisting of member corporations P, S, X, and Y.
(B) Brother-sister controlled group. The outstanding
stock of corporations X and Y, which have only one class of stock
outstanding, is owned by the following unrelated individuals: A owns
40% of X and 20% of Y; B owns 10% of X and 30% of Y; C owns 30% of
X and 40% of Y; D owns 20% of X; and E owns 10% of Y. The result is
that Corporations X and Y have 3 common owners - A, B, and C. D and
E are disregarded from the brother-sister test because they don't
have ownership in both companies. A, B, and C have the following Identical
Ownership (the lesser of X or Y): A has 20%; B has 10%; and C has
30%. A, B, and C meet the identical ownership test because their identical
ownership is more than 50 percent of X and Y.
(C) Combined group.
(i) A, an individual, owns stock possessing 100 percent
of the total combined voting power of all classes of the stock of
corporations X and Y. Y, in turn, owns stock possessing 51 percent
of the total combined voting power of all classes of the stock of
corporation Z. X, Y, and Z are members of the same combined group
since X, Y, and Z are each members of either a parent-subsidiary or
brother-sister controlled group of corporations AND Y is the common
parent of a parent-subsidiary controlled group of corporations consisting
of Y and Z, and also is a member of a brother-sister controlled group
of corporations consisting of X and Y.
(ii) Assume the same facts as in clause (i) of this
subparagraph and further assume that corporation X owns 51 percent
of the total value of shares of all classes of stock of corporation
S. X, Y, Z, and S are members of the same combined group.
(3) Concurrent Employment. M, N, and O are related
corporations which use N as a Common Paymaster. Their respective headquarters
are located in three separate cities several hundred miles apart.
A is an officer of M, N, and O who performs substantial services for
each corporation. A does not work a set length of time at each corporate
headquarters, and when A leaves one corporate headquarters, it is
not known when A will return, although it is expected that A will
return. Under these facts, A is concurrently employed by the three
corporations.
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