Both the leased employee provisions and the management function group rules refer to related persons or organizations. Both provisions use the same definition of “related,” a clause that appears in IRC §144, which deals with certain qualified bonds.
IRC §144, in turn, refers to two other Code provisions which list multiple ways entities can be related. More confusing still, these provisions have their own set of attribution rules, different from the attribution rules affecting controlled groups or affiliated service groups.
As with the controlled group rules, these related person rules have an importance that transcends IRC §414. All or parts of these rules are referred to in many other Code provisions, including the prohibited transaction rules.
 | Q 17:1 What is a related person or organization for management function groups or the leased employee rules? |
| Q 17:2 What does IRC §267 do? |
| Q 17:3 How does IRC §267 treat family members? |
| Q 17:4 How are trusts related to each other and to their beneficiaries and grantors under IRC §267? |
| Q 17:5 How are corporations related to each other and to their owners under IRC §267? |
| Q 17:6 What other entities are related under IRC §267? |
| Q 17:7 What attribution rules are used in applying IRC §267? |
| Q 17:8 Are the attribution rules of IRC §267(c) used elsewhere in pension law? |
| Q 17:9 What does IRC §707(b) do? |
| Q 17:10 How are LLC’s treated for purposes of the related party rules? |