"3-year-old DB plan (combo tested with a PS plan); hard frozen in early 2021 (before 1000 hours accrued) with no accruals and no further new participants. EOY valuation. Top heavy and PBGC covered. Assume that 401(a)(26) will need to be tested. Any reason why I cannot use accrued-to-date method for 401(a)(26)? I just cannot seem to find one but wanted to confirm. Will not test together with the PS plan for 2021 as I do not handle the administration of the PS plan i.e. not sue if historic data is correct or not -- to use acc-to-date method."

"Owner of a professional services firm retires, or almost. All other employees start up a new firm in the same location, same office and start up a new plan. Turns out former owner/retiree is maintaining his old firm for part-time work and still comes to the office. Admin staff still provides services, though currently not clear how much work or if they are getting paid. While reviewing Startup Costs Tax Credit, made me wonder if there is some kind of controlled group issue here, which may affect eligibility for the Tax Credit, as well as nondiscrimination testing, at least."