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Can a foreign plan be a "group health plan" for COBRA?

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I may not be following the right trail of breadcrumbs, but is there an obligation to offer COBRA in the following situation. Foreign company employs several hundred employees. Say the wholly owned US subsidiary only has 5 US employees who are offered a group health plan. The COBRA regulations seem clear that the foreign parent and US subsidiary will be aggregated to determine whether the US subsidiary has 20 employees for COBRA purposes (it does). 

Say the US subsidiary terminates its group health plan altogether, but the foreign parent continues to offer whatever the comparable health insurance is in the foreign parent's country.

Are the 5 US employees entitled to COBRA coverage? Or has the "employer" (which includes the foreign parent) stopped offering any "group health plan" to "any employee" such that COBRA coverage ends?

In other words, does something exclude the foreign coverage from being a "group health plan" for COBRA purposes? I have to assume so - the foreign plan couldn't offer continuation coverage to the US employees - but am not seeing where that result comes from. 

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