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I think you can do this with an 11g amendment. Most likely anyway. Note that the deduction will be deferred for one year.

Just to be sure that this is clear: there is no circumstance under EPCRS in which the employer will make an after-tax corrective contribution. The calculated ADP is a combined ADP for all deferrals (pre-tax and Roth). In your fact pattern, the participant gets one corrective contribution of .5625%, all it pre-tax. Not .5625% for pre-tax, and another .5625% for the Roth. It does not matter if the participant would have elected to make his deferrals as all Roth or all pre-tax, or a combination - there is one corrective QNEC and it is all pre-tax.

This is why I retired 😁

Assuming calendar year plan, if it's late July and the 5500 hasn't been filed yet, there is no reason not to file a 5558 extension. With that done, if you're a day or two late from the October 15 deadline, the penalty counts days back to the July 31 deadline, so you're looking at a minimum of 77 days late, or a $19,250 penalty. The penalty increase was put in the bill as a "revenue raiser" to offset the loss of tax income from other things they wanted to do, like allow retroactive plan adoption and increase the RMD age.

Someone who is a 5% owner in the current or prior year is an HCE. I don't see an exception for attribution but maybe I'm missing one. Therefore, assuming a calendar year plan. The sister would be HCE for 2022 and 2023 but not 2024.

EPCRS and the ADP test are blind to whether a deferral is pre-tax or ROTH eligible, and combine all deferrals into one calculation. The QNEC is an employer allocation(and therefore pre-tax); it will go into an 100% vested Employer source(even if the Plan does not have another Employer source the document allows for QNECs by default), not the deferral source. If the ADP is 2.25% then 25% is .5625%, doing both as you describe would be a 50% QNEC.

Small correction: the increase is not taken into account for purposes of calculating the cushion. Otherwise, it is taken into account.

THe 11(g) does NOT say Group X is increased by some amount, it says PERSON x is increased. There is nothing improper with this amendment nor does it grant rights to a GROUP directly or indirectly. In fact, 11(g) specifically acknowledges this which is why it exists. Also note that this does not affect any accrued benefits because it happens AFTER the year end! It is a retroactive amendment which is why the IRS believes and such contribution is only deductible in the year the amendment is signed. (Side note, I don't think you can do this to a prototype plan because it makes it an individually designed plan.)