- 7 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011