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If a distributing plan has grandfathered and non-grandfathered after tax contributions and the accepting plan only has non-grandfathered dollars (e.g., original effective date of the plan was after 5/5/86), does the accepting plan need to mirror the distributing plan?

If yes, the accepting plan must account for the pre-87 and post-86 after-tax contributions and permit the distribution of the grandfathered dollars first. If no, all the after-tax dollars would be subject to the basis recovery rules.

Usually rollovers come into a plan clean, but the roll over of after-tax dollars are a direct trustee-to-trustee transfer.

Does anyone have experience on how to recordkeeping the rolled over after-tax contributions?

Thanks!

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