For-profit controls not-for-profit - Controlled Group?

414(c)-5 expressly provides for situations where two non-profits can be considered one employer for the purposes of sponsoring a plan together. But it does not expressly provide for a for-profit entity who most likely has control to determine 80% or more of the board at the non-profit to be in a controlled group with one another. Is this situation implied? Can allow the non-profit to adopt the for-profit's qualified retirement plan?

I think 414(c)-5 does cover this situation, Purplemandinga. A for-profit organization that controls at least 80% of the nonprofit's board is an "any other organization" for purposes of Treas. reg. 1.414(c)-5(b).

Thank you Luke,

I clearly was not reading the fine print here.