Company A, an S-corp, is the general partner in several limited partnerships. As a 1% owner, a traditional controlled group situation does not exist. However, as general partner Company A controls the business activity of each limited partnership since the limited partners traditionally have little control. Questions: Do we have have a controlled group since A has more than 80% of the voting power of the limited partnerships? Also, could there possibly be a management affiliated service group here? ? Thanks.

I don't believe there is much clarity in this area. Under Reg. Sec. 1.414©-2(B)(2)(i)©, only the profits and capital interests of a partnership are considered in determining whether it is under common control. "Voting" appears to have no impact. But I've struggled with similar situations.

What were you're conclusions?