Affiliated Service Group - Earned Income

Potential client has ownership interests in a few management companies.  Each company was set up to manage one operating company that has employees.  Each management company receives 100% of its business from the operating company it manages.  Client has no ownership of operating companies and management companies have no employees.

Each pairing is a management affiliated service group.  Payments from operating pass through the management company to an equity holding company.  Equity holding provides client with K-1 self employment income.  This income reflects on 1040 SE.

The management companies are disregarded where the client has self employment income with regard to the management companies? 301.7701-2

Tracing the income to a company within an affiliated service group, does that designation attach to the income , precluding client from adopting a 1-man DB plan in his sole proprietorship with the net earnings?  Or would the client sole proprietorship fall outside the affiliated service group, as the income comes from enough operating companies that the 50% management business is not met?

Doesn't look like anyone else wants to answer, so I'll try. 

First, the 301.7701-2 cite you mention says that single owner entities can be disregarded entities.  Is this person the sole owner of each of the management companies?  If so, you have other complications.  See Derrin Watson's Q&A on overlapping controlled group and affiliated service group.

https://benefitslink.com/cgi-bin/qa.cgi?db=qa_who_is_employer&n=342

To your question, I think the management ASG provision in 414(m)(5) prevents a 1-man plan in a situation like you describe.

I think another rule will prevent it, too.  Look at the definition of 415 compensation in 1.415(c)-2. For a self-employed person, it refers you to the earned income definition in 401(c)(2) and it's regulations. 401(c)(2) says earned income is determined "only with respect to a trade or business in which personal services of the taxpayer are a material income-producing factor".  1.401-10(b)(2) says that if a self-employed person is engaged in more than one trade or business, each trade or business is treated as separate employer for determining earned income and you only count the earned income from the trades or businesses that adopted the plan.  The services here are being preformed for the management companies, which under 414(m)(5) are the same employer as the respective paired operating company.  So, unless one or more of the ASG's adopt the plan, this person will not have any 415(c) compensation, so no plan benefits.  If one or more of the ASG's adopt the plan, I doubt 410(b) and 401(a)(26) would let it be a 1-man plan.