Affiliated Service Group Rules

[Guest CSTS]

We have a situation involving multiple employers that do NOT constitute a controlled group. However, it has been determined that several groups are affiliated service groups. For instance, Employer A and Employer B are an affiliated service group. Also, Employer B and Employer C are an affiliated service group.

Would then, A B and C constitute an affiliated service group? Our situation extends beyond three employers, but this is the basic question we face.

Any thoughts?

[GBurns]

Assuming that these employers are really ASGs, a reading of the text and examples in Proposed Treas Regs 1.414(m)-2(g) seems to say that these are separate ASGs. However there is more facts and analysis that is needed to be sure that there is not aggregation.