“Unitary business group” defined; MCL 208.1117(6); 26 USC § 957; Revenue Admin Bull 2010-1; Attribution rules under 26 USC § 318 of the Internal Revenue Code & § 117 of the Michigan Business Tax Act (MBTA) (MCL 208.1101 et seq.); Statutory construction; United States Fid. Ins. & Guar. Co. v. Michigan Catastrophic Claims Ass’n; Michigan Bell Tel. Co. v. Department of Treasury; Detroit Edison Co. v. Department of Treasury; “Ownership or control” defined; Determining the meaning of terms that are not defined under the MBTA; Town & Country Dodge, Inc. v. Department of Treasury; Consumers Power Co. v. Department of Treasury; Stock ownership; 26 USC § 958; Federal regulations directing that constructive ownership rules are to be applied to determine indirect ownership; 26 CFR §§ 1.382-2T(f)(15) & 1.704-1(b)(2)(iii)(d)(6); Federal regulations directing that constructive ownership rules are used to determine whether “stock is owned (directly or indirectly under the provisions of section 544)”; §§ 1.856-1(d)(5) & 1.861-8T(c)(2)(ii); Delineation between indirect & constructive ownership; § 1.871-14 (g)(2)(iii)(A); § 1.1291-1T(a)(8)(i); § 1.902-1(a)(4)(ii); “Owned indirectly” defined in the context of consolidated returns; § 1.1503(d)-1(b)(19); “Tiering”; In re Air Crash Disaster Near Roselawn (7th Cir.)

In an order, the court amended its published opinion (see e-Journal # 62375 in the 4/4/16 edition) to correct a clerical error. “The word ‘issue’ was omitted after the word ‘dispositive’ in the first sentence of the last paragraph on page 3.” The corrected sentence reads: There is no dispute that the dispositive issue here is what is meant by the phrase “owns or controls, directly or indirectly.” The opinion remained unchanged in all other respects.