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Controlled corporate groups are subject to special tax sharing rules, but they only apply if each corporation of the group files its own separate Form 1120, U. The tax code defines an affiliated group as one in which there is a parent corporation that owns at least 80% of both the voting power and the value of the stock of another corporation and the affiliated group includes all other corporations in which 80% of both the voting power and the value of their stock is owned collectively by other members of the group.