My helmet is on too tight. An active participant has a $100,000 balance in the plan. $25,000 is in voluntary after-tax with $20,000 basis. The rest of the money is pre-tax. Based on the plan document and regulations, the participant is only eligible to take a distribution from the voluntary after-tax source. Can the participant rollover the $25,000 to an IRA(s) with a basis of $20,000 based on this...
Can I roll over just the after-tax amounts in my retirement plan to a Roth IRA and leave the remainder in the plan?
No, you can’t take a distribution of only the after-tax amounts and leave the rest in the plan. Any partial distribution from the plan must include some of the pretax amounts. Notice 2014-54 doesn’t change the requirement that each plan distribution must include a proportional share of the pretax and after-tax amounts in the account. To roll over all of your after-tax contributions to a Roth IRA, you could take a full distribution (all pretax and after-tax amounts), and directly roll over:
pretax amounts to a traditional IRA or another eligible retirement plan, and
after-tax amounts to a Roth IRA.