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  1. TPA Bob
    Have a new client that owned 50% of an insurance agency (S Corporation), his brother the other 50%. He was paid as an independent contractor his commissions from insurance sales to a separate LLP (single member LLP tax as a sole proprietor). The agency has a CEO and CFO separate from either brother. Client has been max funding a SEP for as long as he can remember only on his independent contractor income - no other participants. The insurance agency has a separate retirement plan that she (Client) did not participate in. Do not meet the controlled group rules as do not own more that 50%. A-Org - 1st impression is FSO is the insurance agency, A-Org is my client. Since agency is a corporation appears that it would not be a FSO. B-Org - appears likely Having second thoughts on whether related - sure seems that it should. Conversation greatly appreciated.
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