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Tiered allocation for partnership of professional corporations


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In the case of a partnership of professional corporations we have the following scenario:

- The partnership adopts a cross tested psp

- Each professional corporation(one shareholder only; the doctor)adopts the plan as a participating employer.

- The plan defines the president of each corporation as a separate class. The partnership employees belongs to a separate class also.

Question: is there any way to avoid this arrrangement to be deemed a CODA in the case each adopting employer(prof corp) wants a different allocation?

Thanx for your input

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