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In-Service Distribution of Pick-Up Contributions?


Übernerd
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My understanding is that pick-up contributions are subject to the same limitations on in-service distributions as vanilla employer contributions (i.e., retirement, disability, termination of the plan, etc.), under the general rule that pick-up contributions are treated as employer contributions for plan-qualificaton purposes. Employer, however, is not quite ready to give up hope that there is some mechanism by which they can be distributed in connection with a participant's transfer from one of the employer's plans to another (the way that some mandatory after-tax contributions to DB plans are, see, e.g., Rev. Rul. 60-281). Is there such a mechanism? If so, I haven't been able to find it. Thanks.

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