### Question
How does the law define brother-sister controlled group?


### Answer
Under *26 CFR § 1.1563-1*, **brother-sister controlled group** is defined as:

> two or more corporations if the same five or fewer persons who are individuals, estates, or trusts own (directly and with the application of the rules contained in § 1.1563-3(b)) stock possessing—

(A) At least 80 percent of the total combined voting power of all classes of stock entitled to vote or at least 80 percent of the total value of shares of all classes of stock of each corporation (the 80 percent requirement);

#### Citation:
  - *26 CFR § 1.1563-1*
