Affiliated Service Group/404(a)(7) Issue

[JAY21]

Classic medical Affiliated Service Group (ASG) has an LLC with employees and then 2 professional corps for each of the 2 doctors. All conceded it's an ASG but still want a DB plan in each P.C. and a 7.5% MP plan in the LLC for staff. I can permissively aggregate plans and pass 401(a)(4), but have to still bring in staff at "meaningful" benefit levels into each DB to pass 401(a)(26). I haven't looked at any DB offset arrangement possibilities but let's ignore for this question.

Question: Since I have staff in the DB plans for 401(a)(26) I have common participants so I presume 404(a)(7) combined deduction limitations kick in ? The only reason I'm asking is I don't see a tie in the 414(m) code regarding an ASG being subject to Section 404. Is there any argument that each P.C. can deduct it's own DB contributions (including some staff from the LLC) and the LLC can deduct it's own MP contribution without the ASG group being combined for 404(a)(7) purposes ?

[SRM]

I think it can be done as long as its ASG's but not controlled groups.

[JAY21]

If 414(m) doesn't combine the 3 entities as "one" employer for 404 purposes, then it seems the "P.C.s" are separate employers (for 404 purposes) and since the P.C.s have no common participants in multiple plans (i.e., doctors are not in the MP plan) P.C.'s can deduct their required DB contributions without impacting the MP contribution (which is required too) or triggering non-deductible contributions for the LLC. Perhaps the LLC has the common participants (since some staff is in the DB plans for 401(a)(26) so the LLC may be subject to 404(a)(7) but this isn't any big deal as the LLC's combined MP + DB contributions are easily less than 25% on a stand-alone (LLC) basis. Any thoughts or opinions ?