### Question
How is the term controlled group defined?


### Answer
The term **controlled group** is defined in *26 U.S.C. § 267* as the following:

> given to such term by section 1563(a), except that—


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


(B) the determination shall be made without regard to subsections (a)(4) and (e)(3)(C) of section 1563.

#### Citation:
  - *26 U.S.C. § 267*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter B-Computation of Taxable Income > PART IX-ITEMS NOT DEDUCTIBLE**

