Shared Employees - Where are we these days on this ?

[JAY21]

IRC 414(o) has some minimal language about further regulations being issues to present the avoidance of providing employee benefits through use of Separate Orgs, Leasing arrangements, and "other" arrangements. That's it.

Proposed regs under 414(o) that would include rules for shared employees were withdrawn.

I understand there are some old pre-ERISA Revenue Rulings (Rev Rul 67-101,Rev Ri; 68-391, and Rev Rul 73-447.

Before I spend time reading all these old pre-ERISA Revenue Rulings do you feel these Revenue Rulings are binding at this point ? Is the IRS likely to point to them upon an audit ? I have a new potential DB plan client that we're going to discuss the shared employee issues and want to make sure I know what is binding and what is open to any good faith "reasonable approach". Thanks.