Brother-Sister Controlled Group Question

[Guest EMM118]

Good morning. I'm a benefits attorney who has already looked at "Who's the Employer" and wanted to run a question past the community.

Individual 1 owns 100% of Company A, 0% of Company B, 60% of Company C and 68% of Company D.

Individual 2 owns 0% of Company A, 100% of Company B, 40% of Company C and 32% of Company D.

Individual 1 maintains a retirement plan at Company A.

Individual 2 maintains a retirement plan at Company B.

Employees art C and D are covered under separate elective deferral only 401(k) plans.

If we were only looking at C and D, it looks like a brother-sister controlled group.

Does this change when we look at A, B, C and D?

I am only concerned with the brother-sister issue, as I have concluded that there is no affiliated service group issue.

Thanks very much for your assistance.

Ed

[MSN]

Only C & D are a controlled group. Based on the information provided, no other c.g. exists.

[Guest dbvail]

And then there is the Affiliated Service Group shop of horrors to enter. Just a thought.