The affiliated service group rules do not use the same attribution system used for controlled groups. Instead, they refer to the attribution rules in IRC §318. For a comparison of the attribution systems, see the chart in the Appendix.
The key employee and highly compensated employee (HCE) definitions also reference the IRC §318 attribution rules. In addition, several other employee plan requirements these attribution rules to determine ownership issues. In fact, they are the most frequently used of the three sets of attribution rules. Because of the importance of these rules, not only to ASGs, but also to HCEs and qualified plans in general, they are discussed at length in this chapter.
 | Q 14:1 How do the attribution rules affect whether an organization is part of an ASG? |
| Q 14:2 Where do we find the attribution rules for traditional ASGs? |
| Q 14:3 What types of attribution are there under IRC 318 |
| Q 14:4 Is double attribution allowed under IRC §318? |
| Q 14:5 How is option attribution handled under IRC §318? |
| Q 14:6 Can options be used to make someone an HCE? |
| Q 14:7 How are the family attribution rules applied under IRC §318? |
| Q 4:8 You say these family attribution rules apply for HCEs? But we got rid of family aggregation back with SBJPA. What gives? |
| Q 14:9 How is attribution applied from a partnership to its partners? |
| Q 14:10 How are interests held by estates attributed to beneficiaries? |
| Q 14:11 How are interests held by S Corporations attributed to shareholders? |
| Q 14:12 How are interests held by C Corporations attributed to shareholders? |
| Q 14:13 How are interests held by trusts attributed to beneficiaries? |
| Q 14:14 How is stock held by partners, corporate shareholders, and trust and estate beneficiaries attributed to the entity? |
| Q 14:15 Are any of these rules modified for the key employee or HCE rules? |
| Q 14:16 Besides traditional ASGs, key employees, and HCE rules, how are the attribution rules of IRC § 318 used in qualified plans? |