Rev. Rul. 69-277 says it's okay to distribute voluntary after-tax contributions from a qualified plan at any time. This still appears to be good law, as it is cited as recently as in Notice 2004-12.
How does this interplay with IRS Notice 2014-54? If a plan has both pre-tax and after-tax amounts in it, can a participant withdraw just the voluntary after-tax contributions? Or does 2014-54 require that any distribution (even if no "distributable event," meaning they are still employed, not over 59-1/2, etc.) be a pro rata mix of pre-tax and after-tax?
I keep thinking there must be some way to withdraw just the voluntary after-tax, otherwise 69-277 is useless, but can't figure it out. Does it hinge on a "distributable event" issue?
Any help would be appreciated!