105-68.905—Affiliate.
Persons are affiliates of each other if, directly or indirectly, either one controls or has the power to control the other or a third person controls or has the power to control both. The ways we use to determine control include, but are not limited to—
(e)
A business entity which has been organized following the exclusion of a person which has the same or similar management, ownership, or principal employees as the excluded person.