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Honestly, it requires an introductory course in actuarial mathematics to understand how to calculate an APR from the underlying mortality tables and interest rates. It's not something that you could just slap down a formula and plug in the numbers and get a result. At best, you might be able to use a spreadsheet to calculate the APRs. But if you just download a spreadsheet from somewhere, is that really different from relying on outside software?

We use Relius documents (PPD version). In one of their document seminars, they went through a similar situation and described months of service as simply a passage of time. So, if an employee was employed on the entry date, they entered on that date regardless of how many times they may have been terminated and rehired. If that is the case, I think both of your examples would result in an entry date on the rehire date. (Of course, other documents could be worded differently.)

I'd say yes, he's in your test and needs gateway. But if you test otherwise excludables separately, then perhaps he's not in a test with HCEs. No gateway needed in that scenario, just a one-plan THM.

1. Confirm plan was actually terminated by company action, like a resolution. So that 2019 is really the last year of the plan, rather than it continuing to exist with $0 assets. 2. https://www.irs.gov/retirement-plans/penalty-relief-program-for-form-5500-ez-late-filers has the steps for what/how to file and pay the much cheaper penalty.

It can be self-corrected. Use EPCRS. Some people say to use the DOL calculator, some say no. I was always under the impression, that the calculator could only be used if you are filing under VFCP for late deposits. However, I know many people in the industry use it even if they aren't filing the correction with the DOL.

The basic gist explained in that Sal section (including crossing plan years) is how and for what year you count the compensation as 415 earnings. If that's 415 compensation for 2021 then you'd include her in your 2021 test.