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Church plans and various members of controlled group


Guest mikewebb68
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Guest mikewebb68

Hospitals X and Y are members of the Healthcare System A controlled group. Healthcare System A has already sought an obtained a private letter ruling from the IRS that has established that all retirement plans are Hospital X are "church plans" within the meaning of section 414(e) due to Healthcare System A's status as a 414(e) church and its control of Hospital X. If Healthcare System A controls Hospital Y in the same fashion as it controls Hospital X, are all plans of Hospital Y deemed to be "church plans" as well? Or must an additional private letter ruling be sought to establish whether the retirement plans of Hospital Y are church plans?

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