short limitation year - 415 proration

[Guest JTK]

Let's say I have a short limitation year because I'm switching my limitation year from calendar year to the plan's (non calendar-year) plan year. I know that I need to prorate the 415 limit for the short limitation year. But, have you come across anything that tells me how to allocate employer contributions to that short limitation year in order to test 415 compliance? I make my matching contribution after the end of the plan year. I'm not coming up with anything yet in the regs and Q&As.

Related question:

Doesn't it seem strange that I could have someone who front-loaded his elective deferrals in the short limitation year -- then get hit with a return due to the short plan year proration of the 415 limit? I guess the anwer to that is -- well, "that's the law"!