Mandatory Cash-out and the old look back rule

[Guest PJW]

In applying the old look back rule, does an ESOP have to take dividend distributions into account? For example, under the look back rule the present value of a benefit was deemed to exceed the cash out limit if it exceeded the cash out limit at the time of any previous distribuition. Does anyone know if the payment of a dividend from an ESOP would be considered a distribution for this purpose?