### Question
How is the "parent-subsidiary controlled group" defined?


### Answer
The term **parent-subsidiary controlled group** is defined in *26 U.S.C. § 1202* as follows -

> any controlled group of corporations as defined in section 1563(a)(1), except that—


(i) "more than 50 percent" shall be substituted for "at least 80 percent" each place it appears in section 1563(a)(1), and


(ii) section 1563(a)(4) shall not apply

#### Citation:
  - *26 U.S.C. § 1202*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter P-Capital Gains and Losses > PART I-TREATMENT OF CAPITAL GAINS**

