parent-subsidiary controlled group
(3) Aggregation rules (A) In general All corporations which are members of the same parent-subsidiary controlled group shall be treated as 1 corporation for purposes of this subsection. (B) Parent-subsidiary controlled group For purposes of subparagraph (A), the term “parent-subsidiary controlled group” means any 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 in section 1563(a)(1), and (ii) section 1563(a)(4) shall not apply.