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SECURE 2.0 Act Section 603 Mandatory Roth Catch Up - ADP Testing


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Posted

For traditional tested plans, an ADP test failure can be corrected by recharacterizing excess contributions as catch-up contributions, provided the HCE has not yet reached their maximum catch-up contribution limit for the year.  I have not been able to find much, if anything, on the impact of testing failures where recharacterizing excess contributions as catch-up contributions will cause a the catch-up  to be recharacterized as Roth for those that are HCEs who are also High Income Earners.  If the HCE (is also HIE) made only pre-tax contributions, will recharacterizing excess contributions to catch-up mean that we have to do a Roth Transfer for the catch-up portion?

Posted

See this thread from yesterday:

 

Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance.

Corey B. Zeller, MSEA, CPC, QPA, QKA
Preferred Pension Planning Corp.
corey@pppc.co

Posted

Would the plan adoption agreement need to have In Plan Roth Transfers selected in order to accommodate the recharacterizations of catchups for HCEs who are also HPIs?

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