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Final Regs Issued for Mandatory Roth Catch-Ups for Higher-FICA Wage Participants
Smith, Gambrell & Russell, LLP Link to more items from this source
[Guidance Overview]
Sept. 16, 2025

"In response to questions about what happens if an individual, who has a Deemed Roth Catch-up Election in place, ceases to be an Affected Participant, the Final Regulations note that such a 'Deemed Election' must cease to apply within a 'reasonable period of time' thereafter. Catch-up contributions that were 'deemed' as Roth contributions before the end of the 'reasonable period of time' do not need to be recharacterized as pre-tax catch-up contributions."  MORE >>

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