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Posted

Entity A sponsors a retirement plan.  This employer is now part of a control group due to common ownership with Entity B.   Entity B is a newly formed entity - not a result of a merger or acquisition.   All of the conditions of the grace period are met.  However, I am unclear if the grace period only applies to mergers and acquisitions or if it also applies to newly formed entities.

Posted

You might want to check with an ERISA lawyer familiar with the transition rule's peculiarities.  Over the years, I've been amazed at how liberal IRS has been with respect to this issue.  Can't hurt.

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