I am working with an employer who previously filed Form 5310-A notifying the IRS of its two QSLOBs. In that filing, the employer included an attachment listing each member of its controlled group and assigning each member to either QSLOB #1 or QSLOB #2. The employer is contemplating adding a new subsidiary to its controlled group. The new subsidiary will be part of QSLOB #1. The addition of the new subsidiary will not impact the number of QSLOBs the employer operates.
Does the employer need to file a new Form 5310-A due to the change to the employer’s controlled group? Or can the employer continue to rely upon its previously filed Form 5310-A since there will be no change to the number of QSLOBs it operates? The example in the Form 5310-A instructions of a "modification" necessitating a new filing includes a change to the number of the QSLOBs being operated. I have not been able to find any specific guidance on whether a new filing is needed if the only change is to the controlled group members described in the previous 5310-A attachment.
