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If a plan provides any coronavirus-related distribution, whether the plan restricts it to an elective-deferrals subaccount or allows it from other subaccounts is the plan sponsor's decision.

I don't think there is any mechanism to relieve them of the contribution. If I'm the TPA, that's what I tell them, and say they can consult an ERISA attorney but I don't think they are getting a different answer. I'd keep the plan "open" with the receivable and refuse to prepare a final return until the receivable is satisfied.

If contribution to the profit sharing, per the plan document, was voluntary, then there is probably no disqualification event that could be corrected through EPCRS. If the Plan is worded in a way that the employer is mandated to make a certain level of contribution, then EPCRS might be available to make it retroactive. You haven't put enough facts out there to make a clear determination. Note that I doubt that you could amend prior tax returns to take the 404 deduction in a prior year. I am sorry to hedge, but you will need to get legal counsel involved with this kind of EPCRS correction.

Sorry but I don't think "erroneous failure to allocate" and "forgot to contribute" are equivalent. I thought the EPCRS correction was for required contributions, e.g. SH or a fixed match, but I'm not sure.

The SECURE Act put the restriction into 401(k)(12)(F). I don't think the IRS has the authority to change it. However, if they haven't stopped the SH match yet and are willing to change plan years, they can switch to the SHNEC after the short plan year. Under 1.401(k)-3(e)(3), they can stay safe harbor for the short plan year if they are safe harbor for the plan year before it and the 12 months after it. It doesn't require that they be the same safe harbor for all of those plan years. If they already stopped the SH match, they can change plan years and be SHNEC going forward as long as the first SHNEC plan year is 12 months.

I think the plan administrator is right - the benefit was paid in 2019. Whether or not the participant cashed the check is irrelevant. Was a 1099-R issued?

The popular consensus seemed to be that it would not be permissible. However I don't think there has been anything official one way or the other.

It applies to all types of plans. However it only applies to tax years beginning after 12/31/2019.

No. SECURE removed the notice requirement for the ADP safe harbor of 401(k)(12) and 401(k)(13) but did not remove it for the ACP safe harbor of 401(m)(11) and 401(m)(12).

No. Borrowing is only available to satisfy ACP if the 401(k) portion of the plan is subject to the ADP test. See 1.401(m)-2(a)(6)(ii) No need to switch ACP to current year testing, unless they want to.

Assuming by "adult" you mean 21 or over, you don't attribute stock to the parent or child unless they already own more than 50% of the business. I don't see this meeting the criteria for a CG. WCP