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And if you allocate on balances (which are likely to be bigger for folks with higher compensation), you could very likely have a 401(a)(4) violation.

If every participant is in their own group and the document says that forfeitures reduce contributions one can calculate forfeitures as per the plan document to determine minimum annual additions and then set the otherwise determined individual allocation amount such that the net effect of the forfeiture allocation is subsumed by the client's determination of allocation amount. Yes, it is an annual addition.

in Relius there is an option to allocate forf based on account balance, so, yes at least at one time it is a legitimate basis, though I don't recall seeing it in plan language in recent times. and as I recall you then had to test for nondiscrim. whether you can still do that today I don't know, maybe with special document language. BUT BUT BUT BUT you can't simply allocate forfeitures whatever way you want. the document tells you how to allocate forfeitures. I think most documents say forfs can be used to pay plan expenses as an option, but I think that is different than re-allocating to people like you are trying to do. I thought that was done 'outside' the plan

In 2018 and 2019, you can give up to $15,000 to someone in a year and generally not have to deal with the IRS about it. If you give more than $15,000 in cash or assets (for example, stocks, land, a new car) in a year to any one person, you need to file a gift tax return. One parent could gift-split with another parent and give $30k in one year without having to file a gift tax return.