FishOn Posted September 22 Posted September 22 All this time we have been reading and planning for this provision to start 1/1/2026. However, I saw in the final regs "The final regulations generally will now apply with respect to contributions in taxable years beginning after Dec. 31, 2026." Does this mean that plans do not have to implement this until 1/1/2027? Am I reading this wrong?
RatherBeGolfing Posted September 22 Posted September 22 Recent thread on this. In short, you must comply with the Roth catch-up requirement in 2026 on a reasonable and good faith basis, and you must comply with the final rule in 2027. FishOn, ERISAGirl and ratherbereading 3
austin3515 Posted September 23 Posted September 23 https://www.thebenefitofbenefits.com/2025/09/clarifying-confusion-over-effective-date-for-roth-catch-up-contributions/ Apparently there were some articles out there with bad info... Austin Powers, CPA, QPA, ERPA
Liz Hallam Posted September 23 Posted September 23 Look on page 63 of final regs - real clear - good faith until 1/1/2027. Specifical says administrative transition period IS NOT EXTENDED. ERISAGirl 1
austin3515 Posted September 23 Posted September 23 I am not ashamed to admit I did not make it to page 63 😂😂😂 FishOn, Pension Nerd and Appleby 3 Austin Powers, CPA, QPA, ERPA
Liz Hallam Posted September 24 Posted September 24 Austin - don't be ashamed think it was Kelsey Mayo (ARA) who mentioned in an article. FishOn and austin3515 2
austin3515 Posted September 24 Posted September 24 Yes Kelsey I'm sure made it to the very last page, read the commentary and everything! Austin Powers, CPA, QPA, ERPA
RatherBeGolfing Posted September 24 Posted September 24 23 hours ago, austin3515 said: Apparently there were some articles out there with bad info... A lot of early articles were drafted using an AI summary of the final rule I bet... I had a few different ones summarize for me and all said 2027. Its not always best to be first to publish!
Paul I Posted September 25 Posted September 25 As the saying goes: "Better late and right, than first and wrong." Maybe we need to tweak it a little bit: "Better confirmed late and right, than AI first and wrong." RatherBeGolfing 1
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