Common ownership is not, by itself, a reason to aggregate transactions at the ownership level unless there is commingling of assets or employees, etc., making it appear that the entities act as a unit rather than independently of one another.
I suggest you wait for the new entity to qualify for exemption on its own merits.
On the other hand, if the two entities are not being operated as separate entities (see my first paragraph), I would be VERY RELUCTANT to exempt either of them.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8