Unfreeze 412(e)(3) plan

[slburnett]

Small business (20 people) had a 412(e)(3) plan from 1999 to 2009, at which point the owner didn't have enough money to keep funding - so the plan was frozen as of 11/1/09 (Plan Year 11/1 - 10/31).

Business has picked up, and the owner would like to start making contributions again. Thoughts on what to do with the service between 11/1/09 and 11/1/15? Am I correct in assuming that the amendment could be written to exclude benefit service between those dates if he doesn't want a huge contribution this year? Am I also correct in assuming that if he wants to grant retroactive service, that would be allowed (at the risk of having to fund 6 years worth of benefits)?

Formula is 100% of final 3 at 25 years of service; prorated for service <25.

Thank you!