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Type 2 organization - automatically a controlled group?

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A NFP ["BCO"] created a Type 2 supporting organization* ["BCU"] for itself last year.  According to the accountant, BCU files it's own taxes with it's own EIN and there is a "majority overlap" of the boards, so she is telling us that this should be treated as a controlled group of non-profit organizations.


* "A what?"  Right.  The CPA gave me this link: https://www.irs.gov/charities-non-profits/charitable-organizations/supporting-organizations-requirements-and-types


There are 4 members of BCU's board... two of whom also sit on BCO's board.  BCO is responsible for appointing and removing BCU's board members.

No one told us about this until last week, so even though BCU was established almost a year ago, BCU hasn't adopted BCO's 403(b) plan.  Which is fine, actually - no one from BCU was allowed to defer, and there are no HCEs in BCO, so there is no nondiscrimination issue to worry about.


Does anyone have any experience with these "Type 2 supporting organizations" they'd like to share?  It certainly sounds like a controlled group, but I figured it couldn't hurt to be sure... thanks.

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