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smells like a system to get around covering folks under qualified plans. sounds like such employees are for all practical purposes leased employees Under Code section 414(n), a leased employee is defined as a person who provides services: To a recipient company pursuant to an agreement between the recipient company and the leasing organization, On a substantially full-time basis, and Under the primary direction or control of the recipient company. https://www.irs.gov/retirement-plans/employee-plans-compliance-unit-epcu-leased-employees