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Way more information is needed. Don't assume anything at this point. For example, has this ownership been the same for all years, including 2017? Was company B acquired in a 410(b)(6)(C) transaction, so that a transition period might apply? Are all of the employees ELIGIBLE employees? Perfectly ok to exclude some or all employees of a Controlled group IF you can pass coverage testing. Based upon the ownership you give above, it would appear to be a controlled group now.

Make sure they are trust to trust transfers so as not to violate the one rollover per year rule. That is it should go directly from Plan A -> IRA -> Plan B without the individual taking a cash distribution then writing a check.

Yes, you can roll from IRA into 401(k). There is nothing to correct. There are two distributions here - one from plan A rolled to IRA reported by plan A and another from IRA rolled to plan B which will be reported by the IRA.

They won't lower them because the need the revenue. Even though PBGC premiums go to the PBGC, they count as revenue under the Congressional scoring rules. It was interesting to hear the representatives from ABC on the CCA webcast yesterday. Someone asked them if they considered the long term sustainability of the single employer funding changes and they replied, all they really cared about was getting the multi-employer relief passes and they needed the additional revenue created by the reduction in the single employer contribution requirements to pay for it. No consideration of overall retirement security, just focus on the tax revenue it will create. Interesting when you find out how the sausage gets made.

Consider buying life insurance with LTC rider on each prior to termination?

Agreed on PBGC premiums. It's disappointing that Congress didn't act to stabilize premiums in a similar manner to funding. Hopefully ARA will lobby for it whenever the next round of relief comes up. It's insane that the 1st segment for minimum funding under ARPA for 2021 is now 4.75% while for PBGC premiums it can be as low as 0.51%.

That's correct. Corrective distributions to correct 415, 402(g), or ADP/ACP failures cannot be qualified distributions. https://www.irs.gov/retirement-plans/retirement-plans-faqs-on-designated-roth-accounts

If you have an excess deferral in 2020 and issue the corrective refund after December 31, 2020 but prior to April 15, 2021 you would issue a 2021 Form 1099-R in January of 2022 with code P, indicating that the it is taxable income in 2020.

Agreed. IRS Notice 2009-65 sample amendment for a non-EACA doesn't include any limitations either. https://www.irs.gov/pub/irs-drop/n-09-65.pdf

I'm not aware of one either as a matter of qualification. Other than for QACAs, our pre-approved plan documents do not have any stated maximum or notes in the blanks indicating an upper limit on either auto-enrollment or auto-escalation. I would think at some point you would run up against a practical (or possibly fiduciary?) limit if you tried to auto-enroll everyone at, say, 75% of compensation and then had to take affirmative elections from everyone anyway (and/or field irate phone calls from people who weren't paying attention and had their entire paycheck deferred).

Nope. And there may be issues with a 412(d)(2) amendment as well. If you have an hour, Kevin Donovan did an "Actuarial Grab Bag" webcast a few weeks ago that covers these and other issues and goes through some creative solutions. I highly recommend it. It's on ASPPA's web site.

IRC 401(a)(11). In order for a 401(k) plan to be exempt from the qualified joint & survivor annuity rules, the participant's spouse must be their 100% beneficiary, unless waived.

We had two sets of 5558s sent out the same day in different packages on 7/29/2020. One set is getting the acceptance letter, the other the denial letter. We spoke with the IRS who requested we resend that batch with our proof of mailing. She said in some cases the 5558s got stamped with the day they were opened, and not the postmark of the mailing.