Hi - I am seeking practical feedback on the question of attribution of ownership to minor children. I don't question that IRC section 1563 attributes ownership from parents to children under 21. This creates controlled groups of entirely separate companies simply because they are owned by spouses with minor children. The thing I struggle with are the many cases where the issue goes unnoticed (or is even ignored). I have lost a couple of prospects because they refuse to believe that aggregation is mandatory. For those with existing plans, they often say their TPA never notified them (even in cases where they are confident the TPA is aware of the facts.)
I am curious about others' experience. Do you find this rule is often overlooked? I've never heard of IRS making an issue of it. Have you?