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.

https://www.irs.gov/retirement-plans/rollovers-as-business-start-ups-compliance-project

The link below is an IRS Memorandum Guideline regarding rollovers as business start-ups

https://www.irs.gov/pub/irs-tege/robs_guidelines.pdf

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.