Controlled Group Umbrella Plan

[QDROphile]

A controlled group has a single welfare benefits plan the covers multiple varieties of benefits, such as medical, dental, and life insurance and different versions of coverage for different companies in different states. For example, company A in Maine provides medical and dental insurance to its employees, and company B in Florida provides medical, dental and life insurance to its employees. The coverages and the insurance companies are different in Maine and Florida.

From "Section: Line-by-Line Instructions for the 2006 Form 5500and Schedules" of the instructions to Form 5500:

"A separate Form 5500, with box A(2) checked, must be filed by each employer participating in a plan or program of benefits in which funds attributable to to each employer are available to pay benefits only for that employer's employees, even if the plan is maintained by a controlled group.

A 'controlled group' is generally considered one employer for Form 5500 reporting purposes. A 'controlled group' is a controlled group of corporations under Code section 414(b), a group of trades or businesses under common control under section 414©, or an affiliated service group uner section 414(m)."

How does one reconcile these successive contradictory paragraphs? Does company A file a Form 5500 for its two coverage and company B file a Form 5500 for its three coverages? That squares with the first paragraph. But the second paragraph says that a controlled group is considered a a single employer for purposes of Form 5500, whcih suggests that one Form 5500 is sufficient.

Later instructions say to check box A(2) if the Form 5500 is for a single employer plan, also defined as "an employee benefit plan maintained by one employer ***." So does one plan, the umbrella plan for the controlled group, maintaineed by one employer (a collection of controlled companies), file more than one Form 5500?