EGTRRA and rollovers into a 401(a) plan.

[Belgarath]

I was talking with somebody who recently attended a conference at (Spencers?)

Now remember, this is third-hand, so I can't vouch for complete accuracy. However, there was apparently a gentleman who gave a presentation at this conference, who asserted that 401(a) plans that accepted IRA rollovers would have to separately account for this money, because it remained subject to the "IRA rules." And he apparently used IRC 408(q) as his source for this opinion. I specfically questioned the person I talked to whether he was talking just about IRA contributions under a plan that will allow them, or was he including IRA rollovers, and this person said his presentation included IRA rollovers.

I don't reach the same conclusion from the code, EGTRRA, or the EGTRRA conference committee reports. I see nothing there that indicates this rollover money is still treated as an IRA, and subject to "IRA rules" where they differ from qualified 401(a) plan rules. I just wanted to get some other opinions as to what folks out there think? Thanks!

[davef]

I was at a recent IRS/ASPA conference where the opposite position was taken (i.e., no separate accounting for IRA required). There were several high-ranking IRS officials there who did not argue with that postion. The general concensus was that all rollover amounts become subject to the rules under the plan to which they are transferred -- with an exception for rollovers to gov'tal 457(B) plans.

[Appleby]

The following assets are required to be tracked separately for QPs Deemed IRAs & Qualified Roth Contribution program, as well as rollover of after tax contributions from QPs to IRAs. There are no requirements to track assets rolled from an IRA to a QP.