Related member definition

Related member means a person that, with respect to the taxpayer during all or any portion of the taxable year, is either a related entity, a component member as defined in section 1563(b) of the Internal Revenue Code, or a person to or from whom there is attribution of stock ownership in accordance with section 1563(e) of the Internal Revenue Code except, for purposes of determining whether a person is a related member under this division, "twenty per cent" shall be substituted for "5 percent" wherever "5 percent" appears in section 1563(e) of the Internal Revenue Code.
Related member means a person that, with respect to the
Related member means a person that, with respect to the Taxpayer during any portion of the Taxable Year, is any one of the following: 1. An individual stockholder, if the stockholder and the members of the stockholder’s family (as defined in Section 318 of the Internal Revenue Code, 26 U.S.C. § 318) own directly, indirectly, beneficially, or constructively, in the aggregate, at least 50% of the value of the Taxpayer’s outstanding stock; 2. A partnership, estate, or trust of any partner or beneficiary, if the partnership, estate, or trust, and its partners or beneficiaries own directly, indirectly, beneficially, or constructively, in the aggregate, at least 50% of the profits, equity, capital, stock, or value of the Taxpayer; 3. A corporation, and any party related to the corporation in a manner that would require an attribution of stock from the corporation to the party or from the party to the corporation under the attribution rules of Section 318 of the Internal Revenue Code, 26 U.S.C. § 318, if the Taxpayer owns directly, indirectly, beneficially, or constructively at least 50% of the value of the corporation’s outstanding stock; 4. A corporation and any party related to that corporation in a manner that would require an attribution of stock from the corporation to the party or from the party to the corporation under the attribution rules of Section 318 of the Internal Revenue Code, 26 U.S.C. § 318, if the corporation and all such related parties own in the aggregate at least 50% of the profits, equity, capital, stock, or value of the Taxpayer; or 5. A person to or from whom there is attribution of stock ownership in accordance with Section 1563(e) of the Internal Revenue Code (26 U.S.C. § 1563), except, for purposes of determining whether a person is a Related Member under this paragraph, twenty percent (20%) shall be substituted for five percent (5%) wherever five percent (5%) appears in Section 1563(e) of the Internal Revenue Code.

Examples of Related member in a sentence

  • Related member has $1,000 of receipts: $225 of royalty receipts from Taxpayer, $225 of interest receipts from Taxpayer, $400 of receipts from the sale of goods to Taxpayer, and $150 of miscellaneous receipts.

  • Related member conducts manufacturing operations, licenses intangible property and loans money to Taxpayer.

  • Related member has $1,000 of total receipts: $400 of royalty receipts from the licensing of intangibles, $300 of receipts from the sale of widgets and $300 of receipts from widget repair services.

  • Do not enter the tax rate of a jurisction in which the related member is filing with the taxpayer on a combined or unitary basis.3a Tax rate from related member’s return 3a3b Tax rate from related member’s return 3b3c Tax rate from related member’s return 3c3d Tax rate from related member’s return 3d3e Tax rate from related member’s return 3e4 Related member apportionment percentage(s) for the jurisdiction(s) referenced in line 3.

  • Do not enter the tax rate of a jurisdiction in which the related member is filing with the taxpayer on a combined or unitary basis..3a Tax rate from related member’s return 3a3b Tax rate from related member’s return 3b3c Tax rate from related member’s return 3c3d Tax rate from related member’s return 3d3e Tax rate from related member’s return 3e4 Related member apportionment percentage(s) for the jurisdiction(s) referenced in line 3.


More Definitions of Related member

Related member means a person that, with respect to the taxpayer during all or any portion of the
Related member means a partnership or corporation which:
Related member means a person or entity that, with
Related member means a person that, with respect to the taxpayer during all or any portion of the taxable year, is a related entity, a component member as defined in Section 1563(b) of the Internal Revenue Code, or is a person to or from whom there is attribution of stock ownership in accordance with Section 1563(e) of the Internal Revenue Code.
Related member means a person that, with respect to the entity during all or any portion of the taxable year, is:
Related member means a person that, with respect to the Company during any portion of the taxable year, is any one of the following: 1. An individual stockholder, if the stockholder and the members of the stockholder's family (as defined in Section 318 of the Internal Revenue Code) own directly, indirectly, beneficially, or constructively, in the aggregate, at least 50% of the value of the Company’s outstanding stock. 2. A partnership, estate, trust and any partner or beneficiary, if the partnership, estate, or trust, and its partners or beneficiaries own directly, indirectly, beneficially, or constructively, in the aggregate, at least 50% of the profits, capital, stock, or value of the Company. 3. A corporation, and any party related to the corporation in a manner that would require an attribution of stock from the corporation under the attribution rules of Section 318 of the Internal Revenue Code, if the Company owns directly, indirectly, beneficially, or constructively at least 50% of the value of the corporation's outstanding stock. 4. A corporation and any party related to that corporation in a manner that would require an attribution of stock from the corporation to the party or from the party to the corporation under the attribution rules of Section 318 of the Internal Revenue Code, if the corporation and all such related parties own in the aggregate at least 50% of the profits, capital, stock, or value of the Company. 5. A person to or from whom there is an attribution of stock ownership in accordance with Section 1563(e) of the Internal Revenue Code, except, for purposes of determining whether a person is a related member under this paragraph, 20% shall be substituted for 5% wherever 5% appears in Section 1563(e) of the Internal Revenue Code.
Related member means a person that, with respect to the taxpayer during any portion of the taxable year, is any one of the following: