Mckinney Communications Corporation Employee Stock Ownership Plan

Left in 2017, 2020, 2023, 2024? Worth asking about employer money

• In plan year 2017, 388 people (71% of active participants) left before they were fully vested. Turnover that high can count as a partial plan termination (Revenue Ruling 2007-43), which requires full vesting of employer money for those who left. The plan may argue it was routine turnover. Filing
• In plan year 2020, 506 people (83% of active participants) left before they were fully vested. Turnover that high can count as a partial plan termination (Revenue Ruling 2007-43), which requires full vesting of employer money for those who left. The plan may argue it was routine turnover. A 2021 law (Consolidated Appropriations Act, section 209) can excuse a drop between March 2020 and March 2021 if the plan had rehired enough people by March 31, 2021. Filing
• In plan year 2023, active participants fell from 414 to 235 (43%), and 160 people left before they were fully vested. When a plan loses about 20% or more of its participants in a year, the IRS presumes a partial plan termination (Revenue Ruling 2007-43). Everyone who left in that period must then be fully vested in the employer's contributions. Filing
• In plan year 2024, active participants fell from 235 to 159 (32%), and 44 people left before they were fully vested. When a plan loses about 20% or more of its participants in a year, the IRS presumes a partial plan termination (Revenue Ruling 2007-43). Everyone who left in that period must then be fully vested in the employer's contributions. Filing

This is a reason to ask the plan, not a finding. The plan decides, and it may show the drop was routine.

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