- 211 - We first examine whether INC is a controlled taxpayer within the meaning of section 1.482-1(a)(4), Income Tax Regs. INC was a wholly owned subsidiary of LTD, directly, during the taxable years ended June 30, 1985 and 1986, and indirectly, through the insertion of a holding company, Holdings, during the subsequent taxable years in issue. Consequently, we conclude that LTD controlled INC within the meaning of section 1.482-1(a)(3), Income Tax Regs., and that INC is a controlled taxpayer within the meaning of section 1.482-1(a)(4), Income Tax Regs. Additionally, because the same interests that own LTD also own INC, we conclude that LTD and INC constitute a "group of controlled taxpayers" within the meaning of section 1.482- 1(a)(5), Income Tax Regs. We turn next to whether INC provides the required services pursuant to section 1.482-2(b)(1), Income Tax Regs. INC provides administrative services to LTD. INC handles the daily operations of LTD’s pooled investments program and its funds, performs research and bookkeeping, and produces the monthly client statements. INC and LTD are each members of a group of controlled entities. Consequently, INC provides administrative or other services for the benefit of another member of the group of controlled entities within the meaning of section 1.482- 2(b)(1), Income Tax Regs.31 31 We have previously noted that "sec. 1.482-2(b)(1), Income Tax Regs., applies to a group of controlled 'entities' while sec. (continued...)Page: Previous 201 202 203 204 205 206 207 208 209 210 211 212 213 214 215 216 217 218 219 220 Next
Last modified: May 25, 2011