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Rules Governing Practice before IRS

Designated Roth Accounts - Establishing a Designated Roth Contribution Program

A 401(k), 403(b) or governmental 457(b) plan may permit employees to designate some or all of their plan elective deferrals as after-tax Roth contributions. SARSEP and SIMPLE IRA plans may not offer designated Roth accounts.

To have a designated Roth contribution program, the plan document must be amended to provide:

  • Separate accounts for designated Roth contributions
  • A choice of both pre-tax and Roth elective deferrals
  • That only Roth elective deferrals may be contributed to the designated Roth account (not profit-sharing or employer matching contributions or forfeitures)

Plans offering designated Roth accounts may include:

  • Automatic enrollment of participants (including for designated Roth contributions)
  • Plan loans
  • Employer matching contributions (must be contributed to another account, not to the designated Roth account)
  • In-plan rollovers to designated Roth accounts

Employer matching and profit-sharing contributions

Only employee elective deferrals may be contributed to a designated Roth account. Matching contributions and profit-sharing contributions may not be made directly to the designated Roth account. An employer may use designated Roth deferrals in calculating a matching contribution, but the match amount must be contributed to another account within the plan.

Tax treatment of designated Roth contributions

Designated Roth contributions are treated the same as pre-tax elective deferrals for many purposes, including:

  • The annual contribution limits,
  • Nonforfeitability and distribution restrictions,
  • Nondiscrimination testing,
  • Required minimum distributions, and
  • Calculation of the plan’s deduction limits under Internal Revenue Code Section 404.

Contribute to a Designated Roth Account

Designated Roth Account Distributions

In-Plan Rollovers to Designated Roth Accounts

Additional Resources for Designated Roth Accounts