Pay from any group member counts toward the cap
What the document says“if any person which is a member of such controlled group (other than such publicly held corporation) provides applicable employee remuneration to an individual who is a specified covered employee of such controlled group and the aggregate amount described in subparagraph (B)(ii) with respect to such specified covered employee exceeds $1,000,000--”
The section adds a new paragraph (7) to section 162(m) of the Internal Revenue Code of 1986. For a publicly held corporation in a controlled group the deduction cap is read as covering a specified covered employee, and where another group member pays such an employee and the total across the group tops $1,000,000, the cap applies to that member too and each of them uses an allocable limitation amount in place of $1,000,000.
What the document actually says“if any person which is a member of such controlled group (other than such publicly held corporation) provides applicable employee remuneration to an individual who is a specified covered employee of such controlled group and the aggregate amount described in subparagraph (B)(ii) with respect to such specified covered employee exceeds $1,000,000--”
Pay from another firm in the group counts. The test is whether the total for that person tops $1 million.
The cap then bites on that firm as well. Each firm gets only part of the $1 million. The next rule works out each share.
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