You might want to look at this prior
post that discusses the applicable 410(a) regs.
http://benefitslink.com/boards/index.php?showtopic=4519I think that, as a practical matter, you could probably hold out someone in a profit sharing or MPP Plan until they complete another year under these regs, but you couldn't hold out someone in a 401(k) because there would be no way to put them "back in" the Plan retroactively. I haven't looked at this in a while, but I believe the regs cited in the prior post are the place to begin.