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Excluding from operational definition of affiliate foreign companies which do not stand as entities organized under U.S. law

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For a company which has foreign associations, such as common ownership encompassing various foreign entities, including employing entities which remain unregistered in the USA and lack operations in the USA, could one operationally define the term "affiliate" or "controlled group" to exclude such entities? I particularly ask in consideration of IRC Section 414(b)©(m)(o), as well as limits for section 415 purposes, 416 minimum benefits, identifying HCE, identifying key employees, and so forth. A person could work remotely for such an excluded entity and it would exclude items of compensation.

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