"Under Reg. 1.416-1 Q&A T-30, distributions added to the PVAB means all distributions made by a plan. I understand this to mean one would have to include QDRO distributions in the top heavy determination. Also, I believe a determination of whether or not the ex-spouse (assuming this person is the alternate payee) is a "key or former key employee" must be considered. If the ex-spouse was married to a more than 5 percent owner, then I believe the ex-spouse is considered a "key employee" for top heavy purposes. I believe this has to reviewed in each of the preceding 4 plan years as well to make this determination. Is my understanding correct?"

I don't think the Alternate Payee gets counted as a separate participant for anything, certainly not for purposes of the 5500 form. I think you would "attribute" the prior distribution to the employee/participant.

addendum to above: Section 318(a)(1)(A)(i) relative to members of family state a spouse (other than a spouse who is legally seperated from the individual under a decree of divorce or separate maintenance) is considered as owning stock. Does this apply only in the current year or does it include the 4 preceding plan years (when they were married)? In other words, is the ex-spouse always considered a "non-key employee"?

I agree with Pax. Do not consider that the distribution was made due to a QDRO and that should answer your question.