Taxation (5)

act550_template_ct5_opt1.xlsx

Q1

Suppose that you are the owner of all stock in A-Corp and B-Corp. Now A-Corp owns all of C-Corp and 49% of D-Corp. C-Corp owns the remaining 51% of D-Corp. These are all domestic, includable corporations that have a single class of stock.
Please write your solution in the yellow areas below the question. Perform any support calculations to the right of the yellow areas.
a	Which of the entities are make up an affiliated group?
b	Which of the entities are make up a controlled group?
c	Suppose that A-Corp was a foreign corporation? How would you answer "a" now?

Explain why each case is or is not an affiliated group. All letters refer to domestic corporations that own one class of stock and are includable.
Please write your solution in the yellow areas below the question. Perform any support calculations to the right of the yellow areas.
a	B owns 100% of C. B owns 90% of D. An unrelated party owns 10% of D.
b	B owns 100% of C. B owns 90% of D. C owns 80% of E. D owns 75% of F. Unrelated parties own the balance of the stock.
c	You own 100% of A and B