Aaron is an employee of Corporation X and a participant in X's DB plan. Corporation X is owned 100% by Zelmo, totally unrelated to Aaron.
Aaron also owns 100% of Company Y.
Assuming no ASG, would a loan from plan X to Company Y be a prohibited transaction under §4975(e)(2)(C)?
I think it is.
Would the answer be any different if Company Y were a limited partnership and Aaron 99% limited partner and an unrelated entity 1% GP?