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IRS Notice Prescribes New Rules for In-Plan Rollovers to Roth Accounts
Troutman Sanders Link to more items from this source
[Guidance Overview]
Jan. 9, 2014
"The effective date of the amendment must be prior to or on the date the plan first operates in accordance with the amendment. So, if calendar-year plans allowed in-plan Roth rollovers of otherwise nondistributable amounts in 2013, an amendment to the plan must be adopted no later than December 31, 2014. Notably, this guidance also provides a window until December 31, 2014, for 401(k) safe harbor plans to implement a mid-year amendment (generally prohibited under the 401(k) safe harbor rules) to allow in-plan Roth rollovers."

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