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Application of CG rules to Severance from Employment?


BTG

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For purposes of determining whether a participant has a permissible distribution event under Code section 457(d)(1)(A)(ii) due to severance from employment with the employer, do the controlled group rules apply?  In other words, must a participant terminate employment with all members of the controlled group in order to be eligible for a distribution?  I would think so, since Treas. Reg. section 1.457-6(b)(1) references the regulations under Code section 401(k) (which obviously require a termination with all employers in the controlled group).  Is anyone aware of more specific guidance on this point?

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