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I have a plan where the plan sponsor acquired a new company which does not have a retirement plan. The plan sponsor (buyer) wants to add on the newly acquired company as an adopting employer. They are a controlled group, so no issues there. Since the plan sponsor has a safe harbor plan, are there any issues having the newly acquired company sign on as an adopting employer right away vs. needing to wait to give a 30-day SH notice to the employees of the new company first, or just wait until 1/1/2024? Anything else I'm missing?

The IRS publication goes more in depth on the QSLOBs satisfying two coverage tests, employer-wide and separately with each QSLOB. In this context, the gateway test is satisfied when each QSLOB satisfies nondiscriminatory classification test on an employer-wide basis and also separately for each QSLOB. The cross-testing gateway is something else. I'm hoping someone familiar with QSLOBs can provide some more insight on the application of this, and if there is a nuance I'm missing or misinterpreting. I was also surprised to find the ASPPA book posted!

Hello, I'm looking for clarification on whether or not there is an aggregate employer-wide coverage test that has to be applied in order to qualify as a QSLOB, in addition to passing coverage for each QSLOB separately. Much of what I've read seems to indicate this, referencing a "gateway" test for coverage. From ASPPA DC-3 Study Guide: "If the requirements for QSLOB are met, an employer may elect to apply the coverage tests under IRC §410(b), and, as a result, the nondiscrimination tests of IRC §401(a)(4) separately to each QSLOB. In other words, the purpose of making a QSLOB election is to perform certain testing requirements on a QSLOB-basis rather than on an employer-wide basis. In order to perform the coverage (and thereby nondiscrimination testing) separately, the plan must first satisfy the nondiscriminatory classification requirement of the coverage test under IRC §410(b) on an employer-wide basis." IF the "employer-wide" test is needed, would a controlled group be required to do a control-group-wide coverage test in order to have QSLOBs within the controlled group? The point of confusion is that a reason for having a QSLOB in the first place is to avoid coverage testing on a plan-wide or employer-wide basis. What am I missing? DC-3 Study Guide: https://asppalearningtpabenchmark.org/wp-content/uploads/2020/01/PDF-DC-3-Study-Guide-8th-Edition.pdf Attached is an excerpt from IRS publication found here: https://www.irs.gov/pub/irs-tege/epchd103.pdf IRS QSLOB Coverage Testing.pdf