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5500's & Control Groups of small & large ER's


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2 members of control group share benefits but have their own Life Insurance benefit plans

1 member is > 100

1 member is < 100

it seems from instructions they would file separate 5500's because of the separate Life Insurance benefits.

However, since one member company is < 100 ee's, is it fair to say they do not have to file?

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5500s are filed on the basis of "plans" and not on the basis of employers or related employers.

So a single employer could have 2 life insurance "plans" while a controlled group of employers could share a single "plan".

Do you have a plan document? Very doubtful. So your group life insurance contracts are probably the de facto substitutes for plan documents.

Based on your facts it sounds like you have 2 plans (2 separate group life insurance contracts), only one of which requires a 5500.

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