ESOP Controlled Group?

Company A is a corporation and owns 100% of another corporation Company B. 100% of Company A's stock is held by an ESOP, no employee has a more than 5% ownership interest in the ESOP shares. Does a controlled group exist?

Stock held in the ESOP, (or any other 401(a) Plan) is excluded from the attribution rules.  IRC 318(a)(2)(b).

But would Company A being entirely inside of a ESOP prevent a controlled group from forming with a company that it owns 100% of? I want to think this is still a Parent Subsidiary controlled group of A & B.

2 hours ago, Purplemandinga said:

But would Company A being entirely inside of a ESOP prevent a controlled group from forming with a company that it owns 100% of? I want to think this is still a Parent Subsidiary controlled group of A & B.

If a corporation (A here) owns 100% of another corporation (B here) they are in one controlled group. Doesn't matter than an ESOP owns A.