Related Rollovers

[Guest clh]

Here's our scenario:

Company A leases all employees (including employee owners) from Leasing Company X. Leasing Company X is a not otherwise related to Company A and is engaged in numerous leasing arrangements other than with Company A. The agreement between Company A and Leasing Company X terminates and all leased employees become employees of Company A. All employees are given distribution options, including rollover/transfers to the newly established Company A 401(k) plan.

Is this a related rollover????

It does not appear to fall within the statute, however, something about it just looks like it should be.

Any advice or comments would be appreciated.

Thanks.