Vlad401k Posted August 14, 2015 Posted August 14, 2015 The title basically says it all. Can a plan that does not allow Roth Deferrals allow Roth Rollover into the plan or is that not permitted?
QDROphile Posted August 14, 2015 Posted August 14, 2015 Ater reading the chart, your next question may be "Can a qualified plan have a Designated Roth Account if it does not allow designated Roth contributions?" If you follow the link in the chart you will learn this about Deisgnated Roth Accounts: "A designated Roth account is a separate account in a 401(k), 403(b) or governmental 457(b) plan that holds designated Roth contributions. Designated Roth contributions are elective deferrals that the participant elects to include in gross income. The plan must keep separate accounting records for all contributions, gains and losses in the designated Roth account." Not a perfectly clear answer. Are the designated Roth contributions that are held by the plan the plan's own contributions or is it enough that the rollover is designated Roth contributions of another plan? I think a plan can have a designated Roth account solely for the purpose of holding Roth rollovers, but I am not sure and the IRS chart and its links do not directly address the question.
Belgarath Posted August 14, 2015 Posted August 14, 2015 I think the answer is that the plan must permit Roth deferrals. But, even if you believe otherwise, the question may be moot if you are using a pre-approved document that limits the availability of such a rollover to a plan that permits Roth deferrals.
austin3515 Posted August 14, 2015 Posted August 14, 2015 Our prototype is clear, no Roth rollovers if Roth contributions are not allowed LMOC 1 Austin Powers, CPA, QPA, ERPA
Lou S. Posted August 14, 2015 Posted August 14, 2015 I though the IRS guidance on In-plan ROTH rollovers and In-Plan ROTH conversions pretty clearly stated that you could not have those provisions without also allowing on going ROTH deferrals. I'm not sure if that extends to accepting rollovers from outside or merging in assets from a plan that allows ROTH to one that does not (in a corporate transaction scenario in essence creating a frozen from new contributions ROTH source). LMOC 1
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