Majority Owners
Keywords
More than 50 percent
Controlled group
Combined group
The word "majority" doesn't appear.
The word, "owner" appears 6 times.
Not all of these instances is related to majority ownership.
Relevant instance
Aggregation Rules
Q&A 7 - "Under section 52(a), corporate taxpayers that are members of a controlled group of corporations are treated as a single employer. A controlled group of corporations may be either a parent-subsidiary controlled group, a brother-sister controlled group, or a combined group of corporations."
FN 13 - "A parent-subsidiary controlled group of corporations is one or more chains of corporations where the common parent corporation owns more than 50 percent of the total combined voting power of all classes of stock entitled to vote, or more than 50 percent of the value of all classes of stock of each corporation. A brother-sister controlled group of corporations is two or more corporations where (1) five or fewer persons who are individuals, estates, or trusts own at least 80 percent of the total combined voting power of all classes of stock entitled to vote, or the total value of shares of all classes of stock of each corporation; and (2) the same five or fewer persons, taking into account ownership only to the extent that it is identical with respect to each corporation, own more than 50 percent of the total voting power of all classes of stock entitled to vote, or total value of shares of all classes of stock of each corporation. A combined group of corporations is three or more corporations, each of which is a member of either a parent-subsidiary or a brother-sister controlled group, and at least one of which is both the common parent of a parent-subsidiary controlled group and also a member of a brother-sister controlled group. See Treas. Reg. § 1.52-1"
This notice doesn't contain the word, "majority" or "owner."
This notice doesn't contain the word, "majority" or "owner."
"Specifically, this notice amplifies both Notice 2021-20 and Notice 2021-23 by providing additional guidance on the employee retention credit, applicable to the third 2 and fourth calendar quarters of 2021" (Purpose, pp. 1-2).
The word, "majority" shows up 23 times.
The word, "owner" shows up 40 times.
Not all of these instances is related to majority ownership.
Make sure when you are searching the Notice that you distinguish between owners and majority owners. It is not always evident in the direct section you are reading and requires a close reading before educating the client.
This notice doesn't contain the word, "majority" or "owner."