### Question
Can you define what controlled group means?


### Answer
**Controlled group** is defined as the following in *26 U.S.C. § 1355*:

> any group which would be treated as a single employer under subsection (a) or (b) of section 52 if paragraphs (1) and (2) of section 52(a) did not apply

#### Citation:
  - *26 U.S.C. § 1355*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter R-Election To Determine Corporate Tax on Certain International Shipping Activities Using Per Ton Rate**

