"For plan sponsors with U.S. based operations and exclusively U.S. controlled groups, there is, generally, a healthy awareness of the rules as operations are typically centralized in the U.S. and frequently a single third-party administrator is used for all retirement plans of the controlled group. For foreign based corporations with U.S. subsidiaries ... each company in the U.S. controlled group may have their own retirement plan and cafeteria plan with completely different benefits and separate third-party administrators and none of the parties are aware that a controlled group exists.... The ownership thresholds triggering application of these rules are much lower for [affiliated service groups] than for controlled groups."

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