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When I first read the title, I couldn't figure out how how a cancellation created a powerpoint.

Don't have any precise answer, but this was one area where the statute specifically directed regulations. See Code Section 6432(g)(2) added by Section 9501(b) of the ARP. Relatedly, I have seen some commentary suggesting that in a fully insured plan employers will still continue to pay COBRA premiums to the insurer for all AEIs, and that there is no statutory mechanism for the employer to offset or take credit for those premium payments because the insurer gets the payroll tax credit. My understanding was that the premiums for all AEIs would be treated as being paid (i.e., they pay nothing and the insurance company treats them as being fully paid), then the insurer claims the same amount under the new tax credit. Presumably the employer will provide the insurer a list of AEIs eligible for the subsidy. In that case, why would the employer continue paying the premiums to the insurer for those AEIs? I feel like I must be missing something.

After the correction, they can amend the plan to have 1 YOS and the employee would be out (unless they work(ed) 1,000 hours in a year along the way). Participation is not a protected benefit.

See RP 2019-19, Appendix A.05(2)(d)(i).

In fact I prefer the documents to say if there is no beneficiary and no surviving spouse it list a few types of family members the benefit goes before it says it goes to the estate. Paying benefits to an estate is a major pain for the family involved. Unless there is a state law that helps out often times that means the family has to get an EIN for the estate. You can't send a benefit paid to an estate to an IRA so the estate has to pay taxes. You watch how much work it is to get an estate paid is for a family and you will never fail to complete a beneficiary form ever again.

Short answer, yes, it is generally possible. There are a LOT of plan document and design issues that must be addressed, including compensation period and compensation definition, coverage/nondiscrimination issues, 415 limits, effect on top heavy, etc., etc.

The fact that a government contract was canceled does not, in and of itself, result in a partial plan termination. The PPT is determined starting with a "rebuttable presumption" that all participant terminations are involuntary. You can then prove otherwise, if you can, based on facts and circumstances. Were all these people already 100% vested in all accounts? If so, the PPT has no real effect. There are few absolutes in this arena - see the Matz case. But in most circumstances, if your turnover rate was at least 20% involuntary terminations, then I agree, it is a PPT, barring unusual or egregious circumstances. If, as you say, it was less than 20%, then it would generally not be a PPT. Your situation seems pretty straightforward. Don't forget to take into account the CAA relief, if applicable, with your March 31, 2021 participant count when determining PPT status for 2020.

Related. From the top-heavy regs: T-32 Q. How are rollovers and plan-to-plan transfers treated in testing whether a plan is top-heavy? A. The rules for handling rollovers and transfers depend upon whether they are unrelated (both initiated by the employee and made from a plan maintained by one employer to a plan maintained by another employer) or related (a rollover or transfer either not initiated by the employee or made to a plan maintained by the same employer). Generally, a rollover or transfer made incident to a merger or consolidation of two or more plans or the division of a single plan into two or more plans will not be treated as being initiated by the employee. The fact that the employer initiated the distribution does not mean that the rollover was not initiated by the employee. For purposes of determining whether two employers are to be treated as the same employer, all employers aggregated under section 414(b), (c) or (m) are treated as the same employer. In the case of unrelated rollovers and transfers, (1) the plan making the distribution or transfer is to count the distribution as a distribution under section 416(g)(3), and (2) the plan accepting the rollover or transfer is not to consider the rollover or transfer as part of the accrued benefit if such rollover or transfer was accepted after December 31, 1983, but is to consider it as part of the accrued benefit if such rollover or transfer was accepted prior to January 1, 1984. In the case of related rollovers and transfers, the plan making the distribution or transfer is not to count the distribution or transfer under section 416(g)(3) and the plan accepting the rollover or transfer counts the rollover or transfer in the present value of the accrued benefits. Rules for related rollovers and transfers do not depend on whether the rollover or transfer was accepted prior to January 1, 1984.

You are correct that without a plan specific beneficiary designation the default language in the plan document would determine the order.

If you know the employer's EIN you may be able to check here to see if there is a Form 5500 for a retirement plan https://www.efast.dol.gov/portal/app/disseminatePublic?execution=e1s1 You would input the EIN (without dashes). It is possible to search by name, but I find the results are less consistent. Absence of a Form 5500 doesn't necessarily mean they don't have a 401(k) plan, as there are a variety of reasons why it might not show up, but if there is one listed, you should be able to request a copy of the summary plan description(ask in writing). If they don't give you one, you should ask why - usually the only reason would be if you aren't an eligible participant.

Among other points to consider: If ERISA governs the plan (which might result if there is a non-owner participant, including an eligible employee), the trustee or other fiduciary must maintain the indicia of ownership of the plan’s bitcoin inside the jurisdiction of the district courts of the United States. ERISA § 404(b), 29 U.S.C. § 1104(b). If the retirement plan’s sponsor, administrator, and trustee (with perhaps one human acting in all those roles) seek to maintain the plan as tax-qualified, the trustee might take steps to assure that the trustee, as the plan trust’s trustee, owns the bitcoin. See Internal Revenue Code of 1986 [26 U.S.C.] § 401(a)(2); 26 C.F.R. § 1.401-2, § 1.401(a)-2. Further, the trustee might take steps to assure that the trustee’s ownership of the bitcoin is within the jurisdiction of a State’s court. See 26 C.F.R. § 1.401-1(a)(3). The plan’s administrator and trustee might consider valuation so each Form 5500 report and each actuary’s certificate would report (or refer to) a correct value.