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nor have i, because its brand new, and the document providers are trying to figure out what to draft based on the limited guidance. Prior to the enactment of SECURE 2.0 in December 2022, the only option was that Safe Harbor Match was pre-tax. If the plan allowed, after the match is deposited the participant could convert to Roth Safe Harbor, via a roth conversion or a roth rollover. Otherwise, when the participant gets a distribution of the Safe harbor match amounts paid to themselves, its taxable as income, the same as any other pre-ta Now, with SECURE 2.0, if the plan document allows, and the participant chooses, when the Safe Harbor Match is deposited, it goes in directly to a Roth Safe Harbor source. The participant receives a 1099-R showing it as taxable based on the year it was deposited. See https://www.irs.gov/pub/irs-drop/n-24-02.pdf its taxable if the participant elects the contribution be made as roth. The income is reported on Form 1099-R. If the match is for 2023, and deposited in 2024, for the employee it is taxable as 2024 income. for the participant's tax impact, it doesn't matter what year the benefit accrued, only when it was deposited. the notice from the IRS goes into this, and is definitely worth a read, even though it's 80 pages.

Only if the plan allow and the participant elects it that way. Employer contributions, including safe harbor match, are contributed on a pre-tax basis. They only go in as Roth, in this case Roth Safe Harbor, unless the plan allows for employer contributions as Roth (new with SECURE 2.0) and the participant has chosen for them to be done that way.

Plan permanency is a "thing". It is best discussed with an employer BEFORE the plan is adopted. This takes away the first excuse an employers makes is "no one ever told me so". Is the IRS serious about it? Yes, it's in the regulations and the IRS Manual. See https://www.law.cornell.edu/cfr/text/26/1.401-1 and 1.401-1(b)(2) in particular. Also see the IRS Manual Section 7.12.1.13 Permanency Requirements/Reasons for Termination https://www.irs.gov/irm/part7/irm_07-012-001#idm139730249437392 . This latter link provides a lot of details on what is considered by the IRS in reviewing a plan's permanency, and you will find the answers to your questions and a lot more information. Is this something the IRS even checks? Yes. One way the IRS can learn about the issue is during a review of a company's tax returns. Seeing a deduction for a contribution in one year but not in subsequent years likely will trigger a question. Another way depends in part on whether to plan has filed a Form 5500-EZ, 5500-SF or 5500. The IRS has a formal Entity Control Check that it uses to keep track of filings made year over year. See page 24 of the IFILE User Guide https://www.efast.dol.gov/fip/pubs/EFAST2_IFILE_User_Guide.pdf . The IRS can track filings for the pairing of the employer's EIN and Plan Number. If there are too few or an abrupt end with no designated final filing, this may trigger an inquiry. Keep in mind that a discontinuance of contributions also can lead to a plan being considered terminated. Take a peek at IRM 7.12.1.14. If you convince a plan to delay terminating but the employer makes no contributions, you potentially are making the situation more complicated. Consider cutting your losses with these clients, and focusing your time and resources on educating employers before they sign up.

Funny thing - when I was in high school, I took typing (all right, mostly because the teacher was radiantly attractive) but we had what was, for those days, pretty advanced electric typewriters. I got reasonably good at touch typing. Then when I went to college, all I could afford was this little Underwood manual typewriter, which was about the size of a lunchbox. You couldn't really touch type because you had to hammer the keys, and if you went more than about 20 words per minute, the strikers stuck together, and correcting errors back then wasn't fun. So over the course of 4 years, I lost the ability to type without looking at the keyboard, and have never regained it to this day. It is a source of amusement to my co-workers that I type while holding a pen, in writing position, between the fingers on my right hand. I've thought about doing a video of "Remedial Typing For The Slow Of Wit Dinosaur" but I don't think it would catch on. Boy, did this get off track. My apologies to the original poster.