Page 18 - Large Business IRS Training Guides

Taxpayer’s Aggregate Group

a taxpayer by –
Determine aggregate group for

the controlled group of corporations that
1) Identify
include the taxpayer

• Controlled group means a controlled group as

defined in section 1563 except –

• “more than 50%” replaces “at least 80%”

in section 1563(a)(1);
each place it appears

and

• sections 1563(a)(4) and (e)(3)(C) are not

taken into account

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