Oct 18, 2023
As the Wall Street Journal pithily
summarizes it, "Higher earners age 50 and up will get two more years to
use pretax dollars for all of their retirement savings in 401(k)s and similar
plans, after the Internal Revenue Service delayed a new requirement."
The IRS has announced an administrative transition period
that extends until 2026 the new requirement that any catch-up contributions
made by higher‑income participants in 401(k) and similar retirement plans must
be designated as after-tax Roth contributions.
The IRS has also clarified that plan participants who are
age 50 and over can continue to make catch‑up contributions after 2023,
regardless of income.
According to the guidance, starting in 2024, the new Roth
catch-up contribution rule applies to an employee who participates in a 401(k),
403(b) or governmental 457(b) plan and whose prior-year Social Security wages
exceeded $145,000.
The administrative transition period will help taxpayers
transition smoothly to the new Roth catch-up requirement and is designed to
facilitate an orderly transition for compliance with that requirement,
according to the IRS. The notice also clarifies that the SECURE 2.0 Act
does not prohibit plans from permitting catch-up
contributions, so plan participants who are age 50 and over can still make
catch-up contributions after 2023.
The Treasury Department and the IRS say they will be issuing
future guidance to help taxpayers, and the notice describes several positions
that are expected to be included. As with most IRS announcements, the rules can
be complex. Be sure to get competent advice to make sure you understand
how this change may affect you.
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