Guest Iwonder Posted January 8, 2010 Posted January 8, 2010 A client wishes to maintain separate plans for two company divisions that are separated by several thousand miles but otherwise are engaged in the same business. The two divisions would have different benefits. Can anyone suggest what potentially harmful issues the client should be especially aware of?
Guest Sieve Posted January 8, 2010 Posted January 8, 2010 Unless you can qualify as separate lines of business (under IRC Section 414®), the first 2 issues that come to my mind are minimum coverage and non-discrimination failures. But, if the QSLOB rules work for you, they may well be worth the one-time effort (rather than annual concerns about testing failures).
david rigby Posted January 8, 2010 Posted January 8, 2010 ... coverage being the lesser of the two concerns. You may end up combining these two plans for testing purposes. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
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