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We have a plan that will be terminating in 2021 at some point, date has not been determined.  However, the employer has been sold to new entity and employees are terminated as of 6/30/2021.

The plan is Top-Heavy as of 12/31/2020.  Non-key employee who is a participant and employed by the employer on the last day of the plan year gets a top heavy minimum. 

Is it too simple to say the the plan is terminating as of 11/1/2021 and therefore, no top heavy contribution is required?

I don't want to miss anything being this feels like such an easy question....

Thanks

 

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