Nichol C

My understanding is this would be Code G only. The Form 1099-R instructions say to use Code G for a direct rollover to a designated Roth account, including in-plan Roth rollovers (IRRs). I’m not seeing anything in the instructions that allows Code 2 to be used with G, and it’s not listed as a valid combination in Table 1. Also, the attached IRS In-Plan Roth Rollover Phone Forum transcript (page 13, paragraph 2), while a bit older and from when these rules were first introduced, indicates reporting the amount in Box 1 and 2a with Code G, without mentioning any additional distribution codes. It seems like Code G already communicates that this is a direct rollover and not subject to the 10% early distribution penalty, so adding Code 2 doesn’t appear necessary or supported by the instructions. Happy to be corrected if there’s specific IRS guidance that allows 2G here, but I haven’t come across anything that does. inplan_roth_phoneforum_transcript.pdf

FWIW, I would be cautious about treating this as a new business for the 3 year auto enroll exemption. Even if a new LLC was formed, if it is the same location, same employees, and the same day to day operations, it may look more like a continuation of the old business rather than a brand new startup. It may also matter how the deal was structured, such as a stock or asset purchase, and whether any controlled group rules apply.

You’re reading it correctly. Under the updated rules, a plan can file the 5500-SF if it has fewer than 100 participants with account balances on the first day of the plan year. The only other things I’d check are whether the plan falls into a category that still requires the full 5500... For example, being part of a pooled employer arrangement or holding employer securities.

A lot depends on whether the correct amounts were actually withheld and deposited to the SIMPLE IRA. The deferral percentage should be calculated on gross pay regardless of whether the election was pre-tax or Roth, so it may help to confirm, if you haven’t already, that the correct deferrals were withheld for each pay period. If the correct amounts were withheld and deposited and the only issue was that payroll treated them as after-tax, then it’s really just a payroll clean-up. You’d just want to make sure the year-to-date wages and the W-2s show the right pre-tax treatment. If the correct amounts weren’t withheld or didn’t make it into the SIMPLE IRA, then you’d follow the SIMPLE IRA Fix-It Guide option that best matches the situation, which @justanotheradmin shared above.