Have you ever attended a wedding and tried to figure out who was related to whom? In this day and age, that can sometimes be a difficult task. A similar challenge confronts the benefits professional trying to determine which companies are related for COBRA application.

In a multiple entity setting — especially one where some of the companies have only a handful of employees — the determination becomes critical because of COBRA’s small employer exception. Sifting through the true relatives and the wedding crashers involves a three-step analysis, reviewing one regulation and two sections of the Internal Revenue Code.

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