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It appears there is an exception to the 2 year hold rule for SIMPLE IRA plans that are replaced by a safe harbor 401k mid-year.  However, does the same rule apply if the SIMPLE IRA terminates on 12/31 and the safe harbor 401k is effective 1/1 of the following year.  The exception seems to only apply to mid-year changes. Is that right?

Posted

Does the same rule apply if the SIMPLE IRA terminates on 12/31 and the safe harbor 401k is effective 1/1 of the following year?

My understanding is the exception applies also in this case if the SIMPLE is replaced with a safe harbor 401(k) plan meeting all the rules necessary, even though it is not a mid-year conversion. I think the safe harbor plan would need to remain safe harbor for that following plan year.

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