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Roth Catch-Up Contributions: Final Regs and 415(c) Interactions
American Society of Enrolled Actuaries [ASEA] 
[Guidance Overview] Feb. 12, 2026 "If catch-up contributions are recharacterized under IRC 415(c) and the participant is subject to the Roth requirement, any pre-tax deferrals must be converted to Roth. That means potential tax consequences for the participant.... The Roth catch up requirement can also create potential nondiscrimination challenges." MORE >> |
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