New 5310-A required?

2 hours ago, bblaw said:

I am working with an employer who previously filed Form 5310-A notifying the IRS of its two QSLOBs. In that filing, the employer included an attachment listing each member of its controlled group and assigning each member to either QSLOB #1 or QSLOB #2.  The employer is contemplating adding a new subsidiary to its controlled group. The new subsidiary will be part of QSLOB #1. The addition of the new subsidiary will not impact the number of QSLOBs the employer operates. 

 

Does the employer need to file a new Form 5310-A due to the change to the employer’s controlled group?  Or can the employer continue to rely upon its previously filed Form 5310-A since there will be no change to the number of QSLOBs it operates? The example in the Form 5310-A instructions of a "modification" necessitating a new filing includes a change to the number of the QSLOBs being operated. I have not been able to find any specific guidance on whether a new filing is needed if the only change is to the controlled group members described in the previous 5310-A attachment.

I don't think there is any choice; you are adding a new employer and deciding which QSLOB it belongs to. That's a change in your prior information provided (line 11 stuff).  It won't impact the NUMBER of QSLOBs, but it does impact your determination of who is in each QSLOB, and that's a new determination.  

I have this same question and have not been able to find any guidance.