A corporation may be considered a component member of more than one controlled group (i.e., there may be overlapping groups) If a corporation is a component member of more than one controlled group of corporations with respect to any taxable year, such corporation shall be treated as a component member of only one controlled group. For purposes of this section, if a corporation is a member of more than one controlled group of corporations, such corporation shall be treated as a member of each controlled group. This plan dictates how the aggregate limit will be divided among the component members If a corporation qualifies as a component member of more than one controlled group, it must be treated as a member of only one.
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