Page 41 - Large Business IRS Training Guides

Related Party

• A related party means, with respect to a taxpayer –
• Any 25-percent owner
of the taxpayer,

person who is related (within the meaning of section
• Any
to the taxpayer or any 25-percent
267(b) or 707(b)(1))
owner
of the taxpayer, or

• A controlled taxpayer
within the meaning of Treas. Regs.

together with, or with respect to, the
§1.482-1(i)(5)
taxpayer

any person who owns at least 25% of –
• A 25-percent owner is

of all classes of stock of the corporation
• Total voting power
entitled to vote, or

• Total value of all
classes of stock of the corporation

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