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If more than one corporation would, without the application of this paragraph (c) (2), be a component member of more than one controlled group, those corporations electing to be component members of the same group must file a single statement. If a corporation qualifies as a component member of more than one controlled group, it must be treated as a member of only one. A corporation may be considered a component member of more than one controlled group (i.e., there may be overlapping groups)

If a corporation is a component member of more than one controlled group of corporations with respect to any taxable year, such corporation shall be treated as a component member of only one controlled group. This plan dictates how the aggregate limit will be divided among the component members For purposes of this section, if a corporation is a member of more than one controlled group of corporations, such corporation shall be treated as a member of each controlled group.

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