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#IRC 267 CODE#

An executor of an estate and the beneficiaries of the estate.

Two partnerships in which the same person or persons own, directly or indirectly, more than a 50% capital interest or a 50% profits interest, in both partnerships.

A partnership and a person owning, directly or indirectly, more than a 50% capital interest or a 50% profits interest, in such partnership.

An S corporation and another S corporation or a C corporation if the same person or persons own more than 50% in value of the outstanding stock of each corporation.

more than 50% of the capital interest, or the profits interest, in the partnership.

more than 50% in value of the outstanding stock of the corporation, and.

A corporation and a partnership if the same person or persons own:.

#IRC 267 CODE#

An organization qualified under Section 501 of the Internal Revenue Code (relating to certain educational or charitable non-profit organizations) which is controlled directly or indirectly by a specific person or (if such person is an individual) by members of the family of such individual.Corporation where more than 50% of the value of the stock is owned directly or indirectly by or for one particular trust or by or for the grantor or fiduciary of the trust.A fiduciary of a trust and a beneficiary of the same trust.A fiduciary of one trust and the fiduciary and/or beneficiary of another trust where the same person is the grantor for both trusts.A grantor and a fiduciary of any trust.Two (2) corporations that are in the same controlled group (as defined in subsection (f).Corporation where more than 50% of the value of the stock is owned directly or indirectly by or for one particular individual.Members of the same family unit (siblings, spouse, ancestors, and lineal descendants).The term "related person" or "related party" means any person or party, including entities, that has a relationship to the taxpayer described in Section 267(b) or Section 707(b)(1) of the Internal Revenue Code ("IRC"), including: Definition of Related Parties Pursuant to Sections 267(b) and 707(b)(1)