QSLOB Separate Management Requirement

[Guest ebgroup]

I have spent maybe too much time lately in the regulations related to Code Section 414® and have convinced myself that a controlled group with only two QSLOBs will not generally fail the separate management or separate workforce requirement. I am thinking this because the formula in 1.414®-3 (and definition in 1.414®-11) excludes substantial service employees of the other QSLOB from the denominator. Is it really this simple, or am I missing something? Thanks

[Effen]

Double post -see Retirement Plans General for the open topic.