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FYI: Rev. Proc. 2019-19 supersedes Rev. Proc. 2018-52 https://www.irs.gov/pub/irs-drop/rp-19-19.pdf Keep in mind that this correction program is considered as guidance. If you were not notified until after the end of this year when it was too late to make up the missed deposit, then Appendix A.5(4) would apply (50%). Since you were able to "make up" (at least in part) of the amount missed on you last pay check, then I would think that Appendix A.5(9)(a). As long as they gave you proper notice, no corrective contribution would be due. If your pay was not high enough on your last paycheck to make up the entire amount, then I would think that Appendix A.5(4) would apply that amount you couldn't make up. Since there is not straight answer on this, I would guess that they either (1) chose to meet in the middle of 5(4) or 5(9)(a) at 25%, or (2) chose to apply 5(9)(b) instead.

You may wish to see a lawyer because the IRS 25% safe harbor applies only to missed payments extending more than three months. My reading of the IRS rules, including the Appendix, suggests that, in the case of the shorter period you describe, the erroneous payments should be corrected in whole, e.g., by deduction from your next pay on 12/27. You can also have a lawyer discuss whether there is a fiduciary breach by the employer under ERISA in failing to follow plan documents, including employee elections, even though compliance with an IRS safe harbor protects the plan from disqualification.

I think you are correct. You aren't a shareholder - so you don't benefit from the sale. It just happens that the shares are held by the ESOP. I suppose you could ask for a bonus if you were instrumental in the sale of the company, but I don't have any ideas. I think when small companies are bought or sold the employees don't typically have an expectation that they will benefit monetarily from the transaction. It just happens that a number of them will because of their shares in the ESOP. You aren't one of the lucky ones.

You can amend the formula for the year at any time prior to someone meeting the allocation condition to receive a contribution in the document. Once you have a participant who has reached the allocation condition you can not make it more restrictive for the year or you will have a 411(d) prohibited cutback. In you case once you have a participant credited with 501 hours you are locked in to the contribution. Also because a Money Purchase plan is a Pension plan, make sure you are also in compliance with the 204(h) notice requirements with respect to timing if you cut future accruals.

See here: https://benefitslink.com/cgi-bin/qa.cgi?n=49&db=qa_who_is_employer

You might be able to do an ICHRA.