Comingling Elective Deferrals and Employer Contributions

The 100% owner and only participant is over age 59-1/2.  She has always invested the assets in an account where it was never determined what part constituted deferrals and what part was employer contributions.  Luckily, no withdrawals were ever made before she attained age 59-1/2 or since.  It's unlikely that she will be able to produce the past trust accounting that will enable the establishment of separate balances for each source at this time.  Given her age it would appear that each source would be treated the same in all respects (e.g., distributions, taxation), so as a practical matter would it be acceptable to continue not separating (even just on paper) how much is the deferral balance and how much is not?  As a side note, she will continue to make both types of contributions. 

It doesn't matter until it matters.  And it probably won't ever matter in this case.  That doesn't make it a good idea in other situations.

Assume none of the deferrals are Roth?

4 hours ago, Bird said:

It doesn't matter until it matters.  And it probably won't ever matter in this case.  That doesn't make it a good idea in other situations.

Agreed. But cya with reference to unknown future legislation or regulation.

If it was me, I would make it a three source split going forward:

1. Pre-2020 deferral and profit sharing

2. Deferral

3. Profit Sharing

You can always explain why you can't track pre 2020 contribution, but you should track the contributions you can.

And if her plan allows in-service distributions at 59½, have her roll all that out and start fresh from a 0 balance in each source.

No Roths.  Thanks everyone and have a great weekend!