Leaderboard

Post-transition period, you can aggregate the plans for testing if they use the same method (safe harbor, current year, prior year) to satisfy ADP/ACP. Since the plans together would cover all employees there shouldn't be a coverage issue in that case. If eligible, you could apply for QSLOB status and continue to test them separately. Or, you could just merge the plans into one and forget all this.

Company M as the sponsoring entity will provide their registered physical address for the Doc & 5500. The trustee must be a US entity, either the other owner or a corporate trustee will likely fill that role. Owner A may well qualify as a US Citizen, but his primary residence in a foreign country fogs that status a bit. Unless it will be a participating employer, Company K can likely be ignored as there is no controlled group with Company M, however you will want to rule out Affiliated Service Group as well; or make sure you can treat it as such so you can include it in A's compensation as well. The 1099 contractors are likely questionable. I would have him complete IRS Form SS-8(not to be filed, but for your purposes only), or separately have him answer the questions in Part II, III, & IV. There are a few key indicators in there, one of which they already violate by publicly advertising them as "employees".