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Plan uses a 5 year cliff vesting window.  So contrbutions made on account of work performed in 2017, 2018, 2019, and 2020 will vest on 12/31/2021.  So the 2020 contribution might be in the Plan for less than 12 months.

I know it's a facts and circumstances situation, and I think the structure of this is clearly vesting after future performance of substantial services when you look at the overall structure.  But what about the fact that the last  contribution might be funded during 2021 and vest mere months thereafter?  Is there a minimum period of time that a particular years contributions must be subject to risk of forfeiture? The trail would be very clear that regardless of the timing of the deposit the contribution in the last year is allocable to services rendered in 2020.

I'm surprised I was not able to find anything on point about this...

Austin Powers, CPA, QPA, ERPA

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