### Question
How is the "controlled group of entities" defined?


### Answer
The term **controlled group of entities** is defined in *26 U.S.C. § 3121* as follows -

> a 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 therein, and


(ii) the determination shall be made without regard to subsections (a)(4) and (b)(2) of section 1563

#### Citation:
  - *26 U.S.C. § 3121*
  - Heading: **Subtitle C-Employment Taxes > CHAPTER 21-FEDERAL INSURANCE CONTRIBUTIONS ACT > Subchapter C-General Provisions**

