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IRS Releases Guidance on After-tax Rollovers -- Part 4: Planning Opportunity
FIS Relius Link to more items from this source
Dec. 8, 2014
"The planning device under consideration involves using employee contributions to bring a participant up to the 415 limit who otherwise would not be able to reach that limit because of the deduction and deferral limitations.... Can an employer use this technique if the plan covers other employees, including NHCEs? ... Are the employee contributions subject to the 25% deduction limit or the penalty for nondeductible contributions? ... Are the employee contributions subject to the 415 limit? ... Is there a reason to roll the after-tax contributions to a Roth IRA rather than making an in-plan Roth rollover? ... What plan amendments are needed to implement this strategy? What is the deadline for those amendments?"

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