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IRS Defines Two Types Of Controlled Groups.pdf

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Preview of IRS defines two types of controlled groups
🔗 Source: irs.gov
📊 Size: 481 KB
📄 Pages: 108 pages
⬇️ Downloads: 317

Summary

The Internal Revenue Code established Controlled Groups Provisions in 1964 to encourage small businesses, but some medium and large businesses took advantage of lower tax rates by organizing into multiple corporate forms. The Employee Retirement Income Security Act of 1974 added sections 414(b) and (c), requiring employees of commonly controlled corporations to be treated as employees of a single corporation. Section 1563(a) provides mechanical ownership tests to determine controlled group situations. Section 414(m) addresses employees of an affiliated service group. A controlled group is defined as two or more corporations under common control, with three types: parent-subsidiary, brother-sister, and combination. The controlled group definition applies to determining if a plan meets requirements of sections 401, 408(k), 408(p), 410, 411, 415, and 416. Attribution rules and determination letter programs are also discussed.

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Description

The Internal Revenue Code established Controlled Groups Provisions in 1964 to encourage small businesses, but some medium and large businesses took advantage...

Technical Information

  • File Format: PDF
  • File Size: 481 KB
  • Pages: 108
  • Language: EN
  • Total Downloads: 317
  • Last Updated: 1 week ago

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