expanded affiliated group
(6) Aggregation rule (A) In general Members of an expanded affiliated group shall be treated as a single taxpayer for purposes of applying this subsection. (B) Expanded affiliated group (i) In general For purposes of this paragraph, the term “expanded affiliated group” means an affiliated group as defined in section 1504(a), determined— (I) by substituting “more than 50 percent” for “at least 80 percent” each place it appears, and (II) without regard to paragraphs (2) and (3) of section 1504(b). (ii) Control of non-corporate entities A partnership or any other entity (other than a corporation) shall be treated as a member of an expanded affiliated group if such entity is controlled (within the meaning of section 954(d)(3) ) by members of such group (including any entity treated as a member of such group by reason of this clause).