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Found 3 results

  1. For the A-org test, if the purported FSO is an LLC that has elected to be taxed as a corporation and that is not a professional service corporation (or a professional service LLC), would it fail to be an FSO as a "corporation" that is not a professional service corporation since it is being treated as a corporation for tax purposes? Or would it have to actually be incorporated under state law (and not just treated as a corporation for tax purposes) to be considered a corporation for purposes of this rule?
  2. I have a client with 3 seperate companies. I won't get into the weeds but here are the facts: Company A is FSO with Company C as the A-Org Company B is FSO with Company C as the A-Org Company A & B are not related through ownership, however employees for both A & B do the billing for A & B making them B-Orgs for eachother My question is, since A if affiliated with C (A-Org), B is affiliated with C (A-Org) and A is affiliated with B (B-Org), Are all three related or... Should A be tested with C, B tested with C, and A tested with B? Is it possible to combine all three for testing?
  3. I have a prospective client that wants to do one plan for two employers. There is common ownership, but it is not a controlled group. ABC is an engineering firm. XYZ is a mechanical, electrical and plumbing contractor. ABC provides traditional engineering services for XYZ and XYZ provides design for constructability and budgeting services for ABC (in addition to selling work for ABC). Any thoughts are whether this is an Affiliated Service Group?
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