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I'm assuming this is not a controlled group/affiliated services group? Without doing any research for confirmation, assuming no CG/ASG, I'd say he is non-key until 2016.

Another twist. This Kiplinger article from 2013 - last paragraph: http://www.kiplinger.com/article/retirement/T047-C000-S004-moving-ira-assets-into-a-401k.html Another candidate for a reverse rollover: someone who is still working at age 70 1/2, when required minimum distributions must start. There's an exception to the RMD rule: A worker at that age does not have to take RMDs from the 401(k) of his current employer unless he owns 5% or more of the company. To avoid RMDs while still working, he could roll his IRA and any 401(k)s from former employers into the 401(k) of his current employer. The current 401(k) plan must allow such rollovers.

I may be misinterpreting the question, but I think that the question was more like this: Employee, age 60, terminates from Company A, and begins working at Company B (unrelated to Company A). Rolls 401(k) money from Company A's plan to Company B's plan. Let us assume that the employee also contributes to the Company B plan. Time passes, and the participant, still working for Company B, has attained age 70 1/2. Does the employee have to take a minimum distribution on the portion of the 401(k) balance derived from the Company A rollover, or is the fact that the employee is still working for Company B enough to push off having to start taking RMDs? Would one get a different answer if the employee had not contributed to the Company B plan, so the entire balance in the Company B 401(k) plan is entirely attributable to the rollover from Company A?

Strange scenario. Employer really goofed and did not withhold from employee pay any elective deferrals for 2014. Participants did complete deferral election forms. The Employer, however, did go ahead and make a deposit of those deferral amounts. We have treated this as missed deferrals under the EPCRS Rev Proc. The amounts deposited are now treated as QNECS. Does this now trigger TH and eliminate the exemption so anyone who did not have a missed deferral and therefore, no qnec, now needs TH minimum? I believe it is "yes", but am hoping for an alternative.