contingent worker situation - any thoughts on the stated facts?

[EGB]

Facts: Doctor Group "X" has three valuable and talented management level employees. Other doctor groups realize the value of these employees and would like to utilize their management services as well. Idea is to form a new corp. "A" that would be owned 50/50 by Doctor Group "X" and another unrelated Doctor Group "Y". The three employees would move to A and would perform management services to X and Y on an ongoing basis. (Physically, the employees would remain where they have been). The employees will also perform these services for other doctor groups on both on-going and short-term basis.

Lots of issues.

"A" does not really want to set up its own retirement plans unless it has to.

First, A may be a management service organization with respect to both X and/or Y such that A's employees could participate in either of X or Y's retirement plans. Any thoughts on whether it would constitute an MSO when performing these services for other companies as well?

Second, the employees (after performing these services for one year) could be considered leased employees if the work is done on a substantially full-time basis. Can you be a leased employee of more than one company? I assume not (ie, that you can't be working substantially full time for more than one company).

Third, it could be that they are really independent contractors performing management services to various companies such that A would need its own retirement plan.

I realize that this is very facts and circumstances oriented and that there are no clear answers. I would just like some thoughts on how others may choose to attempt to structure this.

Thanks in advance for any comments.