Department of the Treasury
Internal Revenue Service
Document 7005 (Rev. 4-94)
The technical principles in this publication may be
changed by future regulations or guidelines.
Cat. No. 62847N
Worksheet Number 10 (Form 8388) and this
explanation are designed to aid the specialist in
identifying and resolving issues pertaining to af-
filiated service groups as defined under section
414(m) of the Code.
The general rule of section 414(m) is that
employees of employers that are member of an
affiliated service group are considered to be
employed by a single employer for purposes of
certain provisions of section 401 (a), and sections
408(k), 410, 411, 415 and 416.
I. Required Information
Ill. A Organizations
In the information described in section 5.01 of Rev. Proc.
85-43, 1985-2 C.B. 501, has not been submitted with the
application and there are indications that the plan may be
subject to section 414(m), the information should be re-
quested. If it is not submitted within a reasonable period of
time, this worksheet should not be completed. If the plan is
otherwise qualified, a favorable determination letter should be
issued without a caveat addressing section 414(m). See IRM
7624.1(14). In such instances, the employer may not rely on
the letter for qualification of the plan under section 414(m).
II. Management Organizations
IV. B Organizations
Line a. In order to be a B Organization, a significant portion of
the organization's business must be the performance of
services for an FSO, for one or more A-Orgs. determined with
respect to the FSO, or for both. The services must be of a type
historically performed by employees in the service field of the
FSO or the A-Orgs. Note that an organization may be a B-Org.
even though it does not qualify as a service organization within
the meaning of section 414(m)(3) of the Code. See section
1.414(m)-2(c) of the proposed regulations.
Line b. In addition to satisfying Part IV.a. of the worksheet, 10