Workshop 26 Advanced Affiliated Service Group and Controlled Group Case ...
10/9/2015
Workshop 26 Advanced Affiliated Service Group
and Controlled Group Case Studies
W. Waldan Lloyd Callister Nebeker McCullough
Salt Lake City, Utah 84133 wwlloyd@
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10/9/2015
Affiliated Service Group Rules
? IRC ?414(m)
? Enacted in 1980 as part of the Miscellaneous Tax Act
? Prop. Regs. ?1.414(m)-1 through 4
? Issued February 28, 1983 ? Preamble states that taxpayers may rely on the
proposed regulations, "pending the adoption of final regulations" ? Final regulations have never been issued
Affiliated Service Group Rules
? IRC ?414(m)(5) ? management function rules added
? Enacted in 1982 as part of TEFRA
? Prop. Regs. ?1.414(m)-5 and 6
? Issued in last half of 1987 ? No indication of taxpayer reliance ? Withdrawn in April, 1993
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Affiliated Service Group Rules
? Congressional Intent
? When applying the qualification rules of the Code to retirement plans, certain multiple employer arrangements should be viewed on a combined basis
? The controlled group rules (IRC ??414(b) and (c)) are not broad enough to cover all ownership situations
? Service organizations present particular opportunities for abuses
Affiliated Service Group Rules
? Initial Guidance ? Rev. Rul. 81-105
? Provided examples of how the ASG rules are to be applied
? Rules in Rev. Rul. 81-105 still apply ? Not affected or superseded by the proposed
?414(m) regulations
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Affiliated Service Group Rules
? Basic Rule ? When considering the status of a qualified plan under ?401(a), all employees of the members of an ASG are treated as employed by a single employer
? Basic Rule applies when considering
? ?401(a)(4) ? general non-discrimination ? ?401(a)(5) ? integration ? ?401(a)(17) ? annual compensation limit ? ?401(a)(26) ? minimum participation rule (DB plans)
Affiliated Service Group Rules
? Basic Rule also applies to
? SEPs and Simples - ?408(k) and ?408(p) ? AND also applies the following rules to a qualified
retirement plan: ? Coverage rules ? ?410 ? Vesting rules ? ?411 ? Limitations on accruals ? ?415 ? Top heavy rules ? ?416
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10/9/2015
Affiliated Service Group Rules
? The ASG rules (as well as the controlled group rules under ?414(b) and ?414(c)) also apply (see ?414(t)) to:
? ?79 ? Group term life insurance rules ? ?106 ? Contributions to health plans, MSAs, HSAs
and HRAs ? ?117(d) ? Tuition reduction programs ? ?120 ? Group legal services plans ? ?125 ? Cafeteria plans
Affiliated Service Group Rules
? ASG rules apply to (cont'd)
? ?127 ? Educational assistance plans ? ?129 ? Dependent care assistance programs ? ?132 ? Fringe benefits ? ?137 ? Adoption assistance programs ? ?274(j) ? Deduction limits on employee achievement
awards ? ?505 ? Welfare trust (VEBA) non-discrimination rules ? ?4980B ? Cobra continuation coverage
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