Coronavirus-Related Distribution and Top Heavy

I was wondering if anyone would mind sharing their thoughts on how to handle CRDs with respect to top heavy determinations.

I'm assuming that a CRD for an active employee would be considered as an in-service distribution for top heavy determination.

If that is correct, what happens if the employee rolls the CRD back into the plan?

Is the original distribution still considered an in-service distribution, and the rollover treated as an unrelated rollover?  I wouldn't think you would treat it as both an inservice distribution and a related rollover.

Or is the inservice distribution replaced by the rollover for top heavy determination?

What if the employee took a $100,000 CRD.  Without a rollover back to the plan I would think that would be an inservice distribution for 5 plan years.  That is a static amount for a limited period of time.

If instead the rollover replaces the inservice as a related rollover, that then becomes a fluctuating amount for an indefinite period of time.

One step further, what if the employee only rolls $50,000 of the $100,000 back to the plan.  Is there than a $50,000 inservice distribution for 5 years, and a $50,000 related rollover?

Thanks very much.

Good question. I would assume it is a related rollover for TH testing but the in-service withdrawal is offset but the amount returned to the Plan so as to avoid double counting the amount.