affiliated group ownership tests met
UNDECIDED
0 of 2 settled
- 1ALL OF“the common parent owns directly stock meeting the requirements of paragraph (2) in at least 1 of the other includible corporations, and” § 1504(a)(1)(B)(i) needs Step 2 Ownership of corporation stock meets the requirements of this paragraph UNDECIDED“stock meeting the requirements of paragraph (2) in each of the includible corporations (except the common parent) is owned directly by 1 or more of the other includible corporations.” § 1504(a)(1)(B)(ii) needs Step 2 Ownership of corporation stock meets the requirements of this paragraph UNDECIDED
- 2
Ownership of corporation stock meets the requirements of this paragraph
ALL OFThe ownership of stock of any corporation meets the requirements of this paragraph if it—
“possesses at least 80 percent of the total voting power of the stock of such corporation, and” § 1504(a)(2)(A)“has a value equal to at least 80 percent of the total value of the stock of such corporation.” § 1504(a)(2)(B)