Help--can a 501(c)(18) dist be rolled to an IRA?

[Guest danmar]

I can't find the answer to this anywhere in the code or regs. Reg § 1.402©-2 indicates that pre-tax 501©(18) deferrals cannot be rolled because it does not define 501©(18) as a qualified plan. But, on the other hand, 501©(18) affects 402(g) deferral limits, IRA deductibility, and is subject to certain 401(k) rules. This would suggest that it should be treated as qualified for rollover purposes, too.

Any precedence or citation on this? I am working with a retiring client who very much needs to avoid a big tax hit. Thanks!

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