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Bumppo23

Roth Deferral Amounts; How Do the Circa $1K and Circa $5K Thresholds Stand as Affected?

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https://www.ecfr.gov/cgi-bin/text-idx?SID=3137fd1fa08a2d403ab0fe4ae1922bc3&mc=true&node=se26.6.1_1401_2k_3_61&rgn=div8

https://www.govinfo.gov/content/pkg/CFR-2011-title26-vol5/xml/CFR-2011-title26-vol5-sec1-401k-1.xml

Moreover, a participant's designated Roth account and the participant's other accounts under a plan are treated as accounts held under two separate plans (within the meaning of section 414(l)) for purposes of applying the automatic rollover rules for mandatory distributions under section 401(a)(31)(B)(i)(I) and the special rules in A-9 through A-11 of §1.401(a)(31)-1.
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One infers perhaps that while the deliberation for the less than $1K threshold entails parsing and correlating the Roth account(s) and the remaining accounts of a participant, the less than $5K threshold includes the Roth account(s) and the remaining accounts of a participant together. 

So: Roth accounts of $800 and other accounts of $200; involuntary distribution of a check 

Conversely: Roth accounts of $2,500 and other accounts of $2,600; one lacks the option of an involuntary distribution, entailing amongst others an involuntary rollover 

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Details to amplify the situation: 

https://www.irs.gov/pub/irs-drop/n-10-84.pdf

Q-3. Is an in-plan Roth direct rollover treated as a distribution for all
purposes?


A-3. No. Because an in-plan Roth direct rollover merely changes the
account in a plan under which an amount is held and the tax character of the
amount, a distribution that is rolled over in an in-plan Roth direct rollover is not
treated as a distribution for the following purposes: 

(c) Section 411(a)(11) (relating to participant consent before an immediate
distribution of an accrued benefit in excess of $5,000). The amount rolled over
continues to be taken into account in determining whether the participant’s
accrued benefit exceeds $5,000, and a notice of the participant’s right to defer
receipt of the distribution is not triggered by the in-plan Roth direct rollover. 

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