"The deemed Roth catch-up election offers important advantages over an affirmative election approach.... However, there may be challenges to implementing the deemed Roth catch-up election. Monitoring the IRC section 402(g) limit on a pre-tax only basis for Roth catch-up participants is beneficial in that the effective opportunity may be easier to administer. However, most payroll systems only track the IRC section 402(g) limit on a combined pre-tax and Roth basis. So separately tracking the amount of pre-tax contributions may not be available or may only be feasible after making significant payroll programming changes."  MORE >>