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One of the terminating plans has after-tax and funds of all non-responsive participants is to be rolled over to an IRA account.  Since few part's have funds in after-tax, I believe the after-tax money will needs to be put into ROTH IRA and the earnings into Traditional IRA?

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After tax and Roth are not the same.  I'm not aware of anything that permits you to put after tax money into a Roth IRA.  Interesting though, hard to believe that someone who took the time to make after tax contributions is not responsive.

Ed Snyder

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1 hour ago, Belgarath said:

I think a participant can rollover any part of their distribution to a Roth which is what that seems to be saying.   They just have to accept the tax consequences.  

The question is can the plan force out after-tax to a Roth?

I have not seen that.

I have seen a force out to a regular IRA and working with the IRA company to record the basis that is in the IRA. 

I think the best answer is to put all of the money in a single IRA and get the IRA company to understand there is after-tax money in the IRA that has a basis.  For one thing most of the time two IRAs means two sets of fees to set up the IRA and annual fees.   I would be worried if that is a fiduciary concern if you set something up that has more fees than needed.     I know Millennium Trust Company is able to handle what I just described. 

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