Under to-be-published Notice 2023-62 (which the Bakers and others flag for us), the Internal Revenue Service quiets a few questions.
“[U]ntil taxable years beginning after December 31, 2025, (1) those catch-up contributions [made on behalf of § 414(v)(7)-restricted participants] will be treated as satisfying the requirements of section 414(v)(7)(A), even if the contributions are not designated as Roth contributions, and (2) a plan that does not provide for designated Roth contributions will be treated as satisfying the requirements of section 414(v)(7)(B).”
Further, the IRS practically confirms:
Self-employment income does not count to determine whether a participant is § 414(v)(7)-restricted.
An employer and an administrator may treat a non-Roth election as a Roth election if needed for a catch-up deferral to meet § 414(v)(7).
Some non-aggregation tolerances for a multiemployer or multiple-employer plan about a participant who has more than one participating employer.