"One of the few revenue generators in the legislation [ ('ATRA') ] is an amendment to the Tax Code that expands the availability of 'in-plan Roth conversions' in employer-sponsored retirement plans.... Under ATRA, 401(k), 403(b) and governmental 457(b) plans that include a Roth contribution feature may now offer employees the option of converting any pre-tax amounts held in the plan, including elective deferrals, to after-tax Roth amounts in a taxable 'in-plan Roth conversion,' regardless of whether such amounts are otherwise 'distributable' under the Tax Code. This will greatly expand the potential for taxable conversions of pre-tax amounts to Roth amounts, although it remains to be seen whether this option will in fact generate the amount of tax revenue ($12 billion over the next 10 years) that Congress anticipated when 'scoring' the legislation."

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