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Dalai Pookah

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  1. 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?
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