Multiple ER now a Controlled Group

[fiona1]

Multiple ER plan - 1/1 plan year - 2 employers. In 2007, each employer was tested separately. On 4/1/08, Employer A becomes 100% owned by Employer B - and they are no longer unrelated employers.

How should testing be done for the 2008 plan year? I can see 2 options:

1. Test each employer separately from 1/1/08 to 3/31/08. Then test them together from 4/1/08 to 12/31/08.

2. Test them together from 1/1/08 to 12/31/08 - as they were a controlled group as of the last day of the plan year.

Any thoughts?

[Jim Chad]

FWIW I think it would be correct to test both plans together for whole year.