Whether the corporate records actually show the ownership structure everyone describes, and whether both entities can evidence active operations for the relevant period.
Ask before the adjudicator does
In closely held manufacturing businesses the register and the reality often diverge, because shares moved between family members, a holding company was inserted, or a reorganisation was agreed and never fully documented. The question to put to the accountant and the corporate lawyer is simple: does the paper record support the structure we are about to assert. The second question is about activity — can we produce financial statements, payroll records, contracts and filings showing that each entity is engaged in the regular provision of goods or services.
Both answers should be obtained before a filing date is chosen, because correcting a register properly takes time and cooperation. Backfilling documents after a filing is a worse outcome than delaying it, and it raises questions about the whole file rather than about one requirement.