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^ because there would be no plan sponsor after the corporation dissolves, yes?

The Participant did not exceed the 415 dollar limit, he exceeded the 415 100% of pay limit. Given the serious nature of the examples of egregious failures, I doubt a failure caused by an incorrect estimate of compensation would cause this to be considered egregious. There may still be a problem with eligibility for SCP. Rev. Proc. 2013-12 added a clarification to Section 4.04. To me, it isn't clear cut whether SCP would apply. I would present the options and let the client decide between SCP and VCP.

Which pretty much says the deferrals have to be distributed with earnings. Can this be done under SCP? This is from the EPCRS definitions of an "egregious" failure (which has to be corrected under VCP): (emphasis mine) The member made a deferral that was infinitely larger than the dollar limit. $17,000 / $0.

Why do you hate freedom?