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Roth Catch-Up Rules for Rehires: What Employers Need to Know Under the Final Regs
Faegre Drinker Link to more items from this source
[Guidance Overview]
Jan. 28, 2026

"For employees who are rehired in a different calendar year after separating from service ... review the FICA wages the employer (or aggregated group, if elected) paid to the employee in the calendar year preceding the year of rehire.... [If] the rehired employee did not have any FICA wages from the employer (or aggregated group, if elected) in the prior calendar year, the Roth catch-up requirement does not apply, and the employee may make catch-up contributions on a pre-tax or Roth basis according to plan terms."  MORE >>

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