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IRS Issues Specific Guidance on In-Plan Roth Transfers
FIS Relius
[Guidance Overview] Dec. 16, 2013
"Interestingly, the Notice never uses the phrase 'in-plan Roth Transfer' [(IRT)]. Instead, the Notice expands the concept of [in-plan Roth rollovers (IRR)] to include IRT. So, what we are left with is in-plan Roth rollovers of otherwise distributable amounts (effective in 2010) and in-plan Roth rollovers of otherwise nondistributable amounts (IRT, effective in 2013). The convenience of this approach is that it immediately answers most of the questions about IRT. Just apply the IRR rules that the IRS outlined in Notice 2010-84."
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