QSLOB

[Rob P]

A controlled group had 4 separate entities and a QSLOB filing was done about 10 years ago. Since then each QSLOB tested their plans separately.

We just learned that a fifth entity was brought into the fold in 2002. That entity meets all the SLOB requirements, but no filing was ever done with the IRS.

Question: Do each of the original 4 entities still stand on their own? Meaning, do we need to test each entity separately with the new company (aggregate each QSLOB with the new company), or does the entire controlled group need to be aggregated since 2004?

Thanks.