An expanded affiliated group is generally defined in accordance with the principles of Code section 1504(a) to mean one or more chains of members connected through ownership by a common parent entity if the common parent entity directly owns stock or other equity interests meeting the requirements of Treas. Reg. 1.1471-5(i)(4) in at least one of the other members (without applying the constructive ownership rules of section 318). Generally, only a corporation shall be treated as the common parent entity of an expanded affiliated group, unless the taxpayer elects to follow the approach described in Treas. Reg. 1.1471-5(i)(10).
