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IRS Delays High Earner Roth 401k RequirementIRS Delays High Earner Roth 401k Requirement

By Jason Watson, CPA

Posted Saturday, August 26, 2023

The IRS postponed a SECURE Act provision that would require all those 50 or older who also earn more than $145,000 to be required to make catch-up 401k contributions into their post-tax (Roth) account. The can got kicked down the road until 2026.

The law had some flaws since it is challenging for payroll systems to know how much a taxpayer earned in the previous year. For example, last year, you work at Microsoft and made $100,000 but then quit to work at Google and make another $100,000, and then quit again early in the following year to work for Amazon making $145,000. How is Amazon able to know what Microsoft and Google paid you? Is it just wages? What about bonuses or variable income? Do stock options count or other one and done compensation items?

If the IRS wants to garner more taxes today, shouldn’t the household be considered? Two people in one household, each earning $140,000 is OK but two people in one household with one earning $150,000 and another earning $10,000 is not OK? Seems silly.

According to Vanguard, only 80% of the current 401k plans in the United States offered a Roth 401k contribution option (seriously? It’s been around 18 years). Also, a lot of 401k plans are collectively bargained by labor groups and unions, and to modify a 401k plan is seen as a way for both sides to re-negotiate other provisions in their contract. Messy.

There were some other recordkeeping and compliance challenges with the Roth 401k rule.

The post-tax or Roth component of a 401k plan was added way back in 2006, and is a wonderful investment tool. Your garden-variety Roth IRAs are lousy for two reasons- first, income limits prevent those earning more than $228,000 in 2023 from contributing without using the backdoor option (which always isn’t available given the pro-rata rules). Second, the contribution limit is low at $6,500.

The Roth 401k cuts through both of those limitations. You can earn a zillion dollars and still make Roth 401k contributions, and your contribution limits are $22,500 (for 2023) and $23,000 (for 2024) plus $7,500 in catch-up.

WCG generally recommends post-tax or Roth 401k contributions regardless of income. However, consult your financial advisory and your retirement plan. Here is some more information-

WCG is a full service consultation and tax preparation firm, and we look forward to working with you!