4980 transfer and reversion-more than one tax year

If a plan terminates late in a calendar year and there is overfunding and the goal is to transfer 25% to a QRP and revert the balance to the employer, must everything occur in the same taxable year? Can the transfer and/or the reversion be spread across 2024 and 2025? Could the required 25% be spread across two years?..would this create two seven year clocks? Could the reversion be spread across the two years? A little simpler, can the transfer happen entirely in 2024 and the reversion entirely in 2025?

I do not think you can split a QRP transfer across two years or a reversion. Also, as those transactions are linked, I question whether you could do one in 2024 and the other in 2025. Say you had $100,000 excess, so you need to transfer $25k to QRP and do so in 2024. Then you wait until 2025 to take reversion, to delay the taxes, but you now have $76,000 left in the trust - your QRP falls short of 25%.

Maybe you can split and maybe it doesn't matter, but you're going to have a 2025 final 5500 in either case, so why not just do it all in 2025, unless they want to allocation dollars for 2024. I just think it's risky to do that. I view the entire transaction as one reversion with the direct transfer to the QRP and the other a taxable receipt (like a lump sum with direct rollover portion and a RMD portion).

This is just opinion.