I would not use the Form 8886.
Yes, the retirement plan ownes the corporation
Follow the link below to the IRS website where the ROBS Business Start-Ups Compliance Project provides an overview.
The link below is an IRS Memorandum Guideline regarding rollovers as business start-ups
Like SJRCPA many accountants will not work with ROBS clients because there is a good deal of risk involved. If the client is not working with a company such as Benetrends or Guidant I would definitely stay away. That said there is still no guarantee there will be no issues with the IRS. The key is advoidance of prohibited transactions, meticulous recordkeeping, no S Corp entities only C corps, must be a 401(k) rollover, no IRA's, etc. Do your research and make sure the client is willing to do what is required - administering the plan going forward can be expensive.