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I'd run this past an ERISA attorney

On the other hand, you already have the accrued benefits and assets as of 1/1/2022 thanks to the 12/31/2021 valuation, so it might be less work to use a BOY date. OP didn't mention whether the plan had been previously frozen; if so there is no concern about additional accruals for a 1/1 valuation. If not, then a 412(d)(2) election will allow you to take the freeze and termination into account for the 1/1 valuation.

Company M as the sponsoring entity will provide their registered physical address for the Doc & 5500. The trustee must be a US entity, either the other owner or a corporate trustee will likely fill that role. Owner A may well qualify as a US Citizen, but his primary residence in a foreign country fogs that status a bit. Unless it will be a participating employer, Company K can likely be ignored as there is no controlled group with Company M, however you will want to rule out Affiliated Service Group as well; or make sure you can treat it as such so you can include it in A's compensation as well. The 1099 contractors are likely questionable. I would have him complete IRS Form SS-8(not to be filed, but for your purposes only), or separately have him answer the questions in Part II, III, & IV. There are a few key indicators in there, one of which they already violate by publicly advertising them as "employees".

Those agents started to retire in the 2000's... As for this current crop, they have their checklists to satisfy...😵

Does the plan document say that match and "profit sharing" (why is this in quotes?) will be deposited each pay period? If so you have an operational failure due to failure to follow the plan document, and you can self-correct under the terms of EPCRS - which requires earnings. If the plan document doesn't say that contributions will be deposited each pay period, then I think you should still consider whether you have a potential 401(a)(4) issue, taking into consideration that the right to earnings on contributions is a benefit, right or feature that has to be available on a non-discriminatory basis.

Really? Who would ever think that is a good idea...other than the salesperson? Why would a plan sponsor want to burden themselves with this? Why not just pay a lump sum and if the person really wants a variable annuity, they can buy one outside the plan.