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continuing basis, management
functions for 1 organization (or
for 1 organization and other
organizations related to such 1
organization), and
(B) the organization (and
related organizations) for which
such functions are so performed by
the organization described in
subparagraph (A).
For purposes of this paragraph, the term
“related organizations” has the same meaning
as the term “related persons” when used in
section 144(a)(3).
(6) Other definitions.--For purposes of
this subsection--
(A) Organization defined.--The
term “organization” means a
corporation, partnership, or other
organization.
(B) Ownership.--In determining
ownership, the principles of
section 318(a) shall apply.
[Emphasis added.]
Respondent argues that the MGMT ESOP failed to meet the
minimum participation standards mandated by section 410 beginning
with its plan year ended June 30, 1987. Respondent relies on
MGMT’s affiliation with MFG and the special rules contained in
section 414. Generally, in the case of affiliated service groups
and controlled groups, section 414 requires that all employees of
the members of the group be treated as employed by a single
employer for the purpose of the section 410 minimum participation
standards. Sec. 414(b), (m).
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Last modified: May 25, 2011