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'In-Plan' Roth Conversions (PDF)
Groom Law Group 
[Guidance Overview] Oct. 5, 2010
3 pages. Excerpt: The new Roth conversion feature raises a number of open issues including the scope/timing of the plan amendment, the applicable sourcing and basis allocation rules, the application of the five year holding period for tax-free treatment, reporting and withholding rules, and investment direction issues. Guidance is necessary to properly implement this provision and the timeframe for action is tight.
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