Affiliated Service Group

[thepensionmaven]

My client is a dentist in a dental office shared by two other dentists, each with his own PC.

Some of the employees are shared among the dentists, and that has been addressed and not part of this discussion.

The three dentists own identical interest in a corporation they formed, the sole purpose is for medical billing, paying the office rent, and other joint expenses, etc for each of the dentists.

My client is covering his employees plus his share of the shared employees in his current plan. He also gives a W-2 to two employees who work for the corporation - one is part- time, a few days per week; the other is full-time.

Looking at the ASG/Management Org regs, I would think that this is an ASG situation, my client has to cover the full-time employee who is paid from the separate corporation, but not the PT employee who only works a few days per week.

Or, the employee could waive out (but why would she?) or be excluded from participating, as long as the plan passes 410(b).

Any thoughts??

[rcline46]

I would think the W-2 comes from the three party organization, not your client. Also, 'a few days a week' could easily amount to 1,000 hours in a year, so be careful there.

Although I would agree on the ASG, I athink you need a legal opinion to cover each of the three doctors so that the individual liability is clearly established. just like you did for the shared employees. I would consdider putting a comparable plan into the billing organization equally funded to keep it all fair.