Partial Plan Termination with Short Plan Year

[pixmax]

Client has a 6/30 plan year. As of 1/1/17 ownership will slightly change and they will be closing their facility as of 12/31/16, as it is being moved to another state. Most of the employees will not be relocating and are terminating. Of course this will warrant a partial plan termination. During this time, the client has hired new employees who are from the state in which the new facility will be for training purposes. Client would like to put in a final Profit Sharing Contribution only to those who are part of the original facility and vest them 100%.

My thought is to have a short plan year but since the eligibility is 6 months/monthly entry, those who were hired before 7/1 will be eligible. Is there a way we can exclude them?

The plan is safe harbor with new comparability.

[Tom Poje]

if plan has a 1 year wait, then nobody newly hired will enter anyway

or maybe I am missing something.

[pixmax]

Eligibility is 6 months with monthly entry.

[david rigby]

Can your amendment that awards 100% vesting refer to those who were participants on June 30?