Secure 2.0 catch-up Roth 401K

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xpy1999
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Secure 2.0 catch-up Roth 401K

Post by xpy1999 »

Does anyone know if the "$145,000 in wages" counted as after the regular 401K contribution or before the regular 401K contribution?

"Starting in 2024, individuals that make over $145,000 in wages will no longer be able to make pre-tax catch-up contributions to their employer-sponsored retirement plan. Instead, they will be forced to make catch-up contributions in Roth dollars which means that they will no longer receive a tax deduction for those contributions.

Even though this change will not take effect until 2024, your wage for 2023 may determine whether or not you will qualify to make pre-tax catch-up contributions in the 2024 tax year. In addition, high wage earners may implement tax strategies in 2023, knowing that they are going to lose this sizable tax deduction in the 2024 tax year. "

https://www.greenbushfinancial.com/all- ... cure-act-2
Alan S.
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Re: Secure 2.0 catch-up Roth 401K

Post by Alan S. »

xpy1999 wrote: Mon Jan 30, 2023 9:48 am Does anyone know if the "$145,000 in wages" counted as after the regular 401K contribution or before the regular 401K contribution?

"Starting in 2024, individuals that make over $145,000 in wages will no longer be able to make pre-tax catch-up contributions to their employer-sponsored retirement plan. Instead, they will be forced to make catch-up contributions in Roth dollars which means that they will no longer receive a tax deduction for those contributions.

Even though this change will not take effect until 2024, your wage for 2023 may determine whether or not you will qualify to make pre-tax catch-up contributions in the 2024 tax year. In addition, high wage earners may implement tax strategies in 2023, knowing that they are going to lose this sizable tax deduction in the 2024 tax year. "

https://www.greenbushfinancial.com/all- ... cure-act-2
Sec 603 of Secure 2.0 states the wage definition for purposes of the 145k limit is that of Sec 3121(a).
3121(a) states that deferrals to various retirement plans such as a 401k, 403b, 457b, or SImple IRA are not included wages. Roth 401k contributions are included in wages, therefore if you contribute more to the Roth 401k instead of pre tax, your wage income will be higher and that will increase the chances of your matching contributions also being Roth.
Topic Author
xpy1999
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Re: Secure 2.0 catch-up Roth 401K

Post by xpy1999 »

Thanks a lot, so in essence it is box 1 of W2.
Walkure
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Re: Secure 2.0 catch-up Roth 401K

Post by Walkure »

Alan S. wrote: Mon Jan 30, 2023 10:34 am
xpy1999 wrote: Mon Jan 30, 2023 9:48 am Does anyone know if the "$145,000 in wages" counted as after the regular 401K contribution or before the regular 401K contribution?

"Starting in 2024, individuals that make over $145,000 in wages will no longer be able to make pre-tax catch-up contributions to their employer-sponsored retirement plan. Instead, they will be forced to make catch-up contributions in Roth dollars which means that they will no longer receive a tax deduction for those contributions.

Even though this change will not take effect until 2024, your wage for 2023 may determine whether or not you will qualify to make pre-tax catch-up contributions in the 2024 tax year. In addition, high wage earners may implement tax strategies in 2023, knowing that they are going to lose this sizable tax deduction in the 2024 tax year. "

https://www.greenbushfinancial.com/all- ... cure-act-2
Sec 603 of Secure 2.0 states the wage definition for purposes of the 145k limit is that of Sec 3121(a).
3121(a) states that deferrals to various retirement plans such as a 401k, 403b, 457b, or SImple IRA are not included wages. Roth 401k contributions are included in wages, therefore if you contribute more to the Roth 401k instead of pre tax, your wage income will be higher and that will increase the chances of your matching contributions also being Roth.
Is the catch-up itself a "deferral" for the purposes of Sec 3121(a)?
Consider two employees, Bob and Rob, both age 50. All amounts in 2022 dollars.

In 2023, Bob makes $167,501, and he defers the standard employee contribution of $22,500 to his pretax 401(k), but voluntarily puts his $7,500 catch-up in the Roth 401(k). His 2023 W-2 box 1 after deferral is now $145,001, so he must put his future catch-up in the Roth 401(k) in 2024, and all subsequent years unless his gross income declines.

In 2023, Rob makes $174,999, and he defers the standard employee contribution of $22,500 plus $7,500 catch-up, all to pretax. His 2023 W-2 box 1 is now $144,999, and he can continue to contribute both his standard and catch-up contributions to pretax in 2024 and every year going forward as long as his gross stays steady.

Are these both correct?

Alternate scenario???
In 2023, Rob makes $174,999, and he defers the standard employee contribution of $22,500 plus $7,500 catch-up, all to pretax. However, his plan allows him to immediately do an in-service conversion of $7,500 to the Roth 401(k). This conversion is taxable income in 2023, but not deemed "wage income" and so does not appear on his 2023 W-2 box 1, which still shows $144,999, and he can continue to contribute both his standard and catch-up contributions to pretax in 2024 and every year going forward as long as his gross stays steady.

Is that correct?

As an aside, here's a fun little technical glitch: https://www.napa-net.org/news-info/dail ... %99s-graff :oops:
hamhocs
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Re: Secure 2.0 catch-up Roth 401K

Post by hamhocs »

If it really is Box 1, having HSA contributions taken out through direct deposit vs making them outside could make a difference for some people (me)
biker2035
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Re: Secure 2.0 catch-up Roth 401K

Post by biker2035 »

I am wondering if this new Act allows the match I get into my 401K, can I direct those funds to my workplace Roth 401k instead? Currently contribute to the 401k, but in the past contributed to the Roth 401k.
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Re: Secure 2.0 catch-up Roth 401K

Post by Artsdoctor »

biker2035 wrote: Sat Mar 18, 2023 12:53 pm I am wondering if this new Act allows the match I get into my 401K, can I direct those funds to my workplace Roth 401k instead? Currently contribute to the 401k, but in the past contributed to the Roth 401k.
As I understand it, matches can now occur in your 401k and your Roth 401k. What is new is that your employer can contribute to the Roth 401k (in the past, no).
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Eagle33
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Re: Secure 2.0 catch-up Roth 401K

Post by Eagle33 »

biker2035 wrote: Sat Mar 18, 2023 12:53 pm I am wondering if this new Act allows the match I get into my 401K, can I direct those funds to my workplace Roth 401k instead? Currently contribute to the 401k, but in the past contributed to the Roth 401k.
Starting in 2024, not 2023.
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Harry Livermore
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Re: Secure 2.0 catch-up Roth 401K

Post by Harry Livermore »

Hmmm. I just read about this new rule, but since neither my spouse nor I participate in a 401(k), it won't affect us. I know there are many high-earning Megacorp BH-ers, so I was surprised to only find this one thread, which seemed to peter out after a few posts. Nothing more to say, I suppose... it is what it is.
It's a small number of relatively high-earning folks, presumably in the highest tax brackets, who are likely the very people trying for a bit of tax abritrage as they approach retirement, but I guess there are very few options to avoid it. Plus, it's good to have some money in a Roth, albeit not paid for at the highest tax brackets.
Will this affect anyone here, and is it just a shrug and move on?
Cheers
realclemsongrad
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Re: Secure 2.0 catch-up Roth 401K

Post by realclemsongrad »

Alan S. wrote: Mon Jan 30, 2023 10:34 am
xpy1999 wrote: Mon Jan 30, 2023 9:48 am Does anyone know if the "$145,000 in wages" counted as after the regular 401K contribution or before the regular 401K contribution?

"Starting in 2024, individuals that make over $145,000 in wages will no longer be able to make pre-tax catch-up contributions to their employer-sponsored retirement plan. Instead, they will be forced to make catch-up contributions in Roth dollars which means that they will no longer receive a tax deduction for those contributions.

Even though this change will not take effect until 2024, your wage for 2023 may determine whether or not you will qualify to make pre-tax catch-up contributions in the 2024 tax year. In addition, high wage earners may implement tax strategies in 2023, knowing that they are going to lose this sizable tax deduction in the 2024 tax year. "

https://www.greenbushfinancial.com/all- ... cure-act-2
Sec 603 of Secure 2.0 states the wage definition for purposes of the 145k limit is that of Sec 3121(a).
3121(a) states that deferrals to various retirement plans such as a 401k, 403b, 457b, or SImple IRA are not included wages. Roth 401k contributions are included in wages, therefore if you contribute more to the Roth 401k instead of pre tax, your wage income will be higher and that will increase the chances of your matching contributions also being Roth.
I assume when we mention 401k, solo 401k also have same treatment?
Alan S.
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Re: Secure 2.0 catch-up Roth 401K

Post by Alan S. »

realclemsongrad wrote: Mon Jul 17, 2023 7:51 am
Alan S. wrote: Mon Jan 30, 2023 10:34 am
xpy1999 wrote: Mon Jan 30, 2023 9:48 am Does anyone know if the "$145,000 in wages" counted as after the regular 401K contribution or before the regular 401K contribution?

"Starting in 2024, individuals that make over $145,000 in wages will no longer be able to make pre-tax catch-up contributions to their employer-sponsored retirement plan. Instead, they will be forced to make catch-up contributions in Roth dollars which means that they will no longer receive a tax deduction for those contributions.

Even though this change will not take effect until 2024, your wage for 2023 may determine whether or not you will qualify to make pre-tax catch-up contributions in the 2024 tax year. In addition, high wage earners may implement tax strategies in 2023, knowing that they are going to lose this sizable tax deduction in the 2024 tax year. "

https://www.greenbushfinancial.com/all- ... cure-act-2
Sec 603 of Secure 2.0 states the wage definition for purposes of the 145k limit is that of Sec 3121(a).
3121(a) states that deferrals to various retirement plans such as a 401k, 403b, 457b, or SImple IRA are not included wages. Roth 401k contributions are included in wages, therefore if you contribute more to the Roth 401k instead of pre tax, your wage income will be higher and that will increase the chances of your matching contributions also being Roth.
I assume when we mention 401k, solo 401k also have same treatment?
Yes, if you are an employee receiving W-2 wages (eg from S Corp). But if you are self employed or a partner you are not receiving wages and Sec 603 will not apply.
MBB_Boy
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Re: Secure 2.0 catch-up Roth 401K

Post by MBB_Boy »

I wasn't aware of this at all until the recent WSJ article. A bit surprised I missed it. I suspect its just flown under the radar and a lot of people are going to discover it over the next 6 months
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Re: Secure 2.0 catch-up Roth 401K

Post by queenofthemadhouse »

https://www.mwe.com/insights/wages-by-a ... secure-2-0

This implies it uses Box 5. I’m not sure if there was more guidance since January, or if this interpretation is incorrect.

We are right on the line where my 401k contributions pull us across that line.

If we end up having to go Roth, it won’t be the end of the world, but we are also very close to $160k AGI and have kids in college, so our marginal is very volatile.
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Re: Secure 2.0 catch-up Roth 401K

Post by uaeebs86 »

MBB_Boy wrote: Mon Jul 17, 2023 8:26 am I wasn't aware of this at all until the recent WSJ article. A bit surprised I missed it. I suspect its just flown under the radar and a lot of people are going to discover it over the next 6 months
Same here. It was a bit of a shock, but I haven't been doing enough Roth (vs. tIRA) so now I'll be forced to up it.
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SchruteB&B
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Re: Secure 2.0 catch-up Roth 401K

Post by SchruteB&B »

Harry Livermore wrote: Mon Jul 17, 2023 6:50 am Hmmm. I just read about this new rule, but since neither my spouse nor I participate in a 401(k), it won't affect us. I know there are many high-earning Megacorp BH-ers, so I was surprised to only find this one thread, which seemed to peter out after a few posts.

Will this affect anyone here, and is it just a shrug and move on?
I remember reading in threads about the entire Secure Act 2.0 about this issue months ago, so it was discussed in more than just this one thread.

Spouse has a 401(k) and made first catch up contribution this year so I guess that’s all we get! Currently the workplace does not offer a Roth 401(k) so I imagine they will need to set that up before 2024?

Would rather have access to the extra tax deferred space as it’s now going to be hit 37% federal (and 5% state?) but have been above Roth direct income limits and had rollover IRAs that interfered with backdoor type, so this will be first opportunity to have a Roth.
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Re: Secure 2.0 catch-up Roth 401K

Post by privateID »

I just found out about this recently. I am one of those who falls into this potentially being a concern. I was under $145K in 2022 (when it didn't matter) where almost all of my 401K contributions were in the trad'l 401K. Oddly enough, toward the end of 2022 I decided that I would do some trd'l 401K and some Roth 401K going forward. This year, because of that decision, I will definitely be above the $145K limit (so that affects 2024), but given my desire to do some trad'l and some Roth, this really isn't a big deal.

I find all these limit values to be odd and, to be honest, so far I've been lucky meeting them. When Covid hit, stimulus money was for people who made under $150K (MFJ). Because of my 401K contributions (at the time 100% trad'l), I was under that $150K. My state had an education benefit if you made under $125K, which I did only because my wife lost her job during Covid and the trad'l 401K contributions. Now, with this $145K limit where I am already contributing to a Roth 401K, it seems not to really affect me. I do find these limits to be somewhat arbitrary and to be honest I think they are too high. But that's another story.
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Re: Secure 2.0 catch-up Roth 401K

Post by Alan S. »

Eagle33 wrote: Sat Mar 18, 2023 9:15 pm
biker2035 wrote: Sat Mar 18, 2023 12:53 pm I am wondering if this new Act allows the match I get into my 401K, can I direct those funds to my workplace Roth 401k instead? Currently contribute to the 401k, but in the past contributed to the Roth 401k.
Starting in 2024, not 2023.
Or maybe in 2026! A very large group of interested organizations have requested the IRS to delay this provision and all of its many challenges for 2 more years.

s://www.asppa.org/news/where-we-are-roth-ca ... -provision
Ginny'sMom
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Re: Secure 2.0 catch-up Roth 401K

Post by Ginny'sMom »

Does this apply to household income? How would your company know if your combined AGI is over $145,000?
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Re: Secure 2.0 catch-up Roth 401K

Post by rob »

SchruteB&B wrote: Mon Jul 17, 2023 11:24 am Spouse has a 401(k) and made first catch up contribution this year so I guess that’s all we get! Currently the workplace does not offer a Roth 401(k) so I imagine they will need to set that up before 2024?
If employer does NOT provide a Roth-401K option... My understanding is that you will not be able to contribute the catchup amount - not that they are forced to allow for Roth 401K.
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Re: Secure 2.0 catch-up Roth 401K

Post by uaeebs86 »

Ginny'sMom wrote: Mon Jul 17, 2023 12:35 pm Does this apply to household income? How would your company know if your combined AGI is over $145,000?
401ks are for individuals. I believe this is tied to your salary not your AGI.
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Re: Secure 2.0 catch-up Roth 401K

Post by Alan S. »

Ginny'sMom wrote: Mon Jul 17, 2023 12:35 pm Does this apply to household income? How would your company know if your combined AGI is over $145,000?
No, the 145k limit is per person, and uses the prior year Box 5 amount of the person's W-2 to determine if the current year catch up contribution for the same employer must be Roth. Therefore, the employer only needs to check their prior year W-2.
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401(k) Catch-up Contribution Rules Are Changing

Post by Cocoa Beach Bum »

[Thread merged into here --admin LadyGeek]

I noticed this WSJ article today:
High-Earning Retirement Savers Are Losing Some of Their 401(k) Tax Break
Catch-up contributions will have to be done after taxes for those who make more than $145,000

Changes are supposed to kick-in on Jan 1, 2024.
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Re: Secure 2.0 catch-up Roth 401K

Post by newbh933 »

Harry Livermore wrote: Mon Jul 17, 2023 6:50 am It's a small number of relatively high-earning folks, presumably in the highest tax brackets, who are likely the very people trying for a bit of tax abritrage as they approach retirement, but I guess there are very few options to avoid it. Plus, it's good to have some money in a Roth, albeit not paid for at the highest tax brackets.
Will this affect anyone here, and is it just a shrug and move on?
Cheers
It will affect me, but I don't mind since I needed to increase my Roth contributions for the next few years anyway and already max out Roth IRA contributions. So in light of that, I switched my catch-up contributions to go to the Roth portion of my 401K a few paychecks ago. Figured I might as well get started early. I'll probably switch some portion of my regular 401K contributions to Roth as well in the near future. But I need to figure out what I can afford taxwise.
But looks like some financial institutions might need some more time to get caught up. Currently, there's no way for me to see the current balance for the Roth portion of my 401K (my plan is run by Principal). It shows that's how I've allocated my catchup contribution, but no way to see the balance. I have an active help request out to them asking about this.
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Re: 401(k) Catch-up Contribution Rules Are Changing

Post by Harmanic »

This could create some planning headaches for people who are borderline, since they might not know their income until near the end of the year. Just another complexity in the tax code.
The question isn't at what age I want to retire, it's at what income. | - George Foreman
solarcub
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Re: 401(k) Catch-up Contribution Rules Are Changing

Post by solarcub »

Did they say which line on the 1040 is the one that counts for the $145,000 cutoff?
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Re: Secure 2.0 catch-up Roth 401K

Post by little_star »

Alan S. wrote: Mon Jul 17, 2023 12:19 pm
Eagle33 wrote: Sat Mar 18, 2023 9:15 pm
biker2035 wrote: Sat Mar 18, 2023 12:53 pm I am wondering if this new Act allows the match I get into my 401K, can I direct those funds to my workplace Roth 401k instead? Currently contribute to the 401k, but in the past contributed to the Roth 401k.
Starting in 2024, not 2023.
Or maybe in 2026! A very large group of interested organizations have requested the IRS to delay this provision and all of its many challenges for 2 more years.

s://www.asppa.org/news/where-we-are-roth-ca ... -provision
I can see why the investment firms would like more time to prepare for this new rule. As with any "cliff-based" rule, the edge cases are going to be the most difficult to implement. Consider the newly turned 50 yo who hasn't given a thought to catch-up contributions, but has a set percentage going to tax deferred. If that percentage results in $22,501 being withheld, $1 would be diverted to a (new) Roth 401k, assuming the person is over the $145k salary limit. Depending on how the accounts are set up, this could result in many nuisance accounts with very small balances due to slight overages. Further, at my place, we have separate employer tax-deferred, employee tax-deferred, and employee Roth accounts, so figuring out where to direct the monthly contributions will pose a potential challenge (pro-rated between tax-deferred and Roth?, all tax-deferred until $22.5k reached and then all Roth? etc). Preparing for the range of possibilities presumably leads to a major headache for HR and the investment firms.
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Re: 401(k) Catch-up Contribution Rules Are Changing

Post by sailaway »

Harmanic wrote: Mon Jul 17, 2023 1:33 pm This could create some planning headaches for people who are borderline, since they might not know their income until near the end of the year. Just another complexity in the tax code.
It uses prior year income to make the determination. And I believe it is specifically prior year income at that specific employer.
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Re: Secure 2.0 catch-up Roth 401K

Post by LadyGeek »

I merged Cocoa Beach Bum's thread into a similar discussion.
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Harmanic
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Re: 401(k) Catch-up Contribution Rules Are Changing

Post by Harmanic »

sailaway wrote: Mon Jul 17, 2023 1:40 pm
Harmanic wrote: Mon Jul 17, 2023 1:33 pm This could create some planning headaches for people who are borderline, since they might not know their income until near the end of the year. Just another complexity in the tax code.
It uses prior year income to make the determination. And I believe it is specifically prior year income at that specific employer.
That's a relief. Thanks!
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Re: 401(k) Catch-up Contribution Rules Are Changing

Post by btq96r »

Maybe I missed it in the article, but are they going to change the contribution period for the calendar year being up until taxes are due like with an IRA? People on the bubble will need time to get their W2 and confirm how much they can contribute if they know it's not cut and dry to start a year when they lock in their deductions with each paycheck.

They really need to add that in for a change like this.
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Re: Secure 2.0 catch-up Roth 401K

Post by SchruteB&B »

rob wrote: Mon Jul 17, 2023 12:41 pm
SchruteB&B wrote: Mon Jul 17, 2023 11:24 am Spouse has a 401(k) and made first catch up contribution this year so I guess that’s all we get! Currently the workplace does not offer a Roth 401(k) so I imagine they will need to set that up before 2024?
If employer does NOT provide a Roth-401K option... My understanding is that you will not be able to contribute the catchup amount - not that they are forced to allow for Roth 401K.
Yes, didn’t mean to imply any employer MUST provide a Roth 401(k) option but I am pretty confident this employer will want to add one, this is going to affect many at this workplace.
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Re: Secure 2.0 catch-up Roth 401K

Post by OuterBanks »

Worst timing ever for this catch-up law change. I just reached catch-up age and my income likely going to be a few dollars over $145,000 by the end of this year. Would my traditional 401K contributions count as deductions to lower my income looked at by this new law?
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Re: Secure 2.0 catch-up Roth 401K

Post by queenofthemadhouse »

It looks like your regular 401k contributions do not reduce your income for this purpose, but things like medical insurance, FSA and HSA contributions are subtracted. It appears to be Compensation used for Medicare taxes (Box 5 on your W2).
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Re: Secure 2.0 catch-up Roth 401K

Post by Grogs »

The timing is pretty lousy for me, and I'm hoping for the 2-year delay. For 2023-4, I'm living out of state (paying 6% state tax vs. 0% back home) for work and I'm receiving a really large reimbursement on my housing costs that adds nearly $80k to my taxable income. The extra housing pushes me from 24% to 32%, plus an extra 6% of state tax, plus possibly NII means I'll pay an extra 12%+ (36%+ marginal) on the catch-up. I don't anticipate ever being in this high of a tax bracket again (barring significant increases in future tax brackets), so it's literally the worst possible time to do Roth contributions.

By 2026 the extra housing reimbursements and state tax will be gone from my paycheck, and I would just pay the flat 24% on the Roth catch-up. I probably won't be much lower than that in retirement (I estimate 22% if the current rates hold), so Roth vs. Traditional @ 24% marginal seems pretty neutral.
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Re: Secure 2.0 catch-up Roth 401K

Post by apezam »

So is it Box 1 or Box 5 on W2?
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Que1999
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Re: Secure 2.0 catch-up Roth 401K

Post by Que1999 »

Does this affect the 457 catch-up clause at all?

"Special 457(b) catch-up contributions, if permitted by the plan, allow a participant for 3 years prior to the normal retirement age (as specified in the plan) to contribute the lesser of:

the elective deferral limit ($22,500 in 2023; $20,500 in 2022; $19,500 in 2020 and in 2021).
the basic annual limit plus the amount of the basic limit not used in prior years (only allowed if not using age 50 or over catch-up contributions)"

This is my second year of catch-up contributions prior to retirement at 44 years old, if that makes any difference.
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Re: Secure 2.0 catch-up Roth 401K

Post by Alan S. »

Que1999 wrote: Mon Jul 17, 2023 8:15 pm Does this affect the 457 catch-up clause at all?

"Special 457(b) catch-up contributions, if permitted by the plan, allow a participant for 3 years prior to the normal retirement age (as specified in the plan) to contribute the lesser of:

the elective deferral limit ($22,500 in 2023; $20,500 in 2022; $19,500 in 2020 and in 2021).
the basic annual limit plus the amount of the basic limit not used in prior years (only allowed if not using age 50 or over catch-up contributions)"

This is my second year of catch-up contributions prior to retirement at 44 years old, if that makes any difference.
From Mercer Consulting:
Special catch-up contributions under 403(b) and 457(b) plans. Certain 403(b) and 457(b) plans can allow additional catch-up contributions above the limit that ordinarily applies. SECURE 2.0 is unclear, but the Roth catch-up mandate doesn’t appear to apply to these special catch-up contributions.
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Que1999
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Re: Secure 2.0 catch-up Roth 401K

Post by Que1999 »

Alan S. wrote: Mon Jul 17, 2023 10:11 pm
Que1999 wrote: Mon Jul 17, 2023 8:15 pm Does this affect the 457 catch-up clause at all?

"Special 457(b) catch-up contributions, if permitted by the plan, allow a participant for 3 years prior to the normal retirement age (as specified in the plan) to contribute the lesser of:

the elective deferral limit ($22,500 in 2023; $20,500 in 2022; $19,500 in 2020 and in 2021).
the basic annual limit plus the amount of the basic limit not used in prior years (only allowed if not using age 50 or over catch-up contributions)"

This is my second year of catch-up contributions prior to retirement at 44 years old, if that makes any difference.
From Mercer Consulting:
Special catch-up contributions under 403(b) and 457(b) plans. Certain 403(b) and 457(b) plans can allow additional catch-up contributions above the limit that ordinarily applies. SECURE 2.0 is unclear, but the Roth catch-up mandate doesn’t appear to apply to these special catch-up contributions.
Thank you!
rationalactor
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Re: Secure 2.0 catch-up Roth 401K

Post by rationalactor »

One upside appears to be that if an employer offers a Roth 401k option and an after tax contribution option, along with the opportunity to do in plan conversions from after tax to Roth, then in theory one could get much more into Roth, since the total limit for all contributions (including after tax ones plus any employer matching funds, and incorporating the catch up), is now up to $73,500. For example:

Pretax 401k contribution: $22,500
Roth catch up: $7,500
After tax contribution: up to $43,500 (with immediate in-plan Roth conversion potential if plan permits).

I suppose this opportunity was available before Secure 2.0, too, if a plan offered a Roth option and in plan conversions. But it seems based on the WSJ piece that a lot more employers will be offering Roth options as a result of Secure 2.0. Assuming they also offer after tax and in plan Roth conversion options to go with the new Roths, then employees of those companies adding the Roths have a new, administratively simple means of getting a lot into their Roth 401k accounts. All that assumes of course that the employee can afford to contribute the extra $43.5k! But since we are talking about high earners in this thread that may be feasible for some. Add in annual backdoor Roth IRA contributions of $15k (if married) or $7.5k (if single) with the current IRA catch up amounts and you have the potential to significantly amp up Roth contributions with just a few mouse clicks…
queenofthemadhouse
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Re: Secure 2.0 catch-up Roth 401K

Post by queenofthemadhouse »

I think that employer level limitations on after-tax contributions were a bigger barrier to the Mega Back door than Roth provisions.
worthit
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Re: Secure 2.0 catch-up Roth 401K

Post by worthit »

rationalactor wrote: Tue Jul 18, 2023 5:14 am One upside appears to be that if an employer offers a Roth 401k option and an after tax contribution option, along with the opportunity to do in plan conversions from after tax to Roth, then in theory one could get much more into Roth, since the total limit for all contributions (including after tax ones plus any employer matching funds, and incorporating the catch up), is now up to $73,500. For example:

Pretax 401k contribution: $22,500
Roth catch up: $7,500
After tax contribution: up to $43,500 (with immediate in-plan Roth conversion potential if plan permits).

I suppose this opportunity was available before Secure 2.0, too, if a plan offered a Roth option and in plan conversions. But it seems based on the WSJ piece that a lot more employers will be offering Roth options as a result of Secure 2.0. Assuming they also offer after tax and in plan Roth conversion options to go with the new Roths, then employees of those companies adding the Roths have a new, administratively simple means of getting a lot into their Roth 401k accounts. All that assumes of course that the employee can afford to contribute the extra $43.5k! But since we are talking about high earners in this thread that may be feasible for some. Add in annual backdoor Roth IRA contributions of $15k (if married) or $7.5k (if single) with the current IRA catch up amounts and you have the potential to significantly amp up Roth contributions with just a few mouse clicks…
Interesting. So is this better than the pre-tax contributions for those high earners who otherwise would get a tax deduction?
Harri88
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Re: Secure 2.0 catch-up Roth 401K

Post by Harri88 »

Question, if my catch-up contributions go into a Roth 401k. Is there any impact to contributions for my Roth IRA?
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Eagle33
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Re: Secure 2.0 catch-up Roth 401K

Post by Eagle33 »

Harri88 wrote: Tue Jul 18, 2023 4:03 pm Question, if my catch-up contributions go into a Roth 401k. Is there any impact to contributions for my Roth IRA?
IMHO, no.
cshell2
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Re: Secure 2.0 catch-up Roth 401K

Post by cshell2 »

Harri88 wrote: Tue Jul 18, 2023 4:03 pm Question, if my catch-up contributions go into a Roth 401k. Is there any impact to contributions for my Roth IRA?
The only way I could see that happening is if you are near the limit to direct contribute to a Roth IRA and go over due to AGI increasing from 401K catch up switching to Roth. Otherwise, they are two separate things with separate limits. Contributing to a Roth 401K doesn't reduce what you can put in a Roth IRA.
mikejuss
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Re: Secure 2.0 catch-up Roth 401K

Post by mikejuss »

This is such an annoying new rule; I would much prefer to fund a catch-up with pretax money. That said, I would hope that Roth 401(k) money can be rolled into a Roth IRA for simplicity's sake.
50% VTSAX, 25% VTIAX, 25% VTEAX
mikejuss
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Re: Secure 2.0 catch-up Roth 401K

Post by mikejuss »

worthit wrote: Tue Jul 18, 2023 9:26 am Interesting. So is this better than the pre-tax contributions for those high earners who otherwise would get a tax deduction?
In a word, no. High earners are better off getting the tax break.
50% VTSAX, 25% VTIAX, 25% VTEAX
rationalactor
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Re: Secure 2.0 catch-up Roth 401K

Post by rationalactor »

mikejuss wrote: Tue Jul 18, 2023 9:18 pm
worthit wrote: Tue Jul 18, 2023 9:26 am Interesting. So is this better than the pre-tax contributions for those high earners who otherwise would get a tax deduction?
In a word, no. High earners are better off getting the tax break.
Yes; tax break better for sure. With tax break reduced, more Roth opportunities with great administrative simplicity as more plans make this maneuver easy a slight consolation prize.
Alan S.
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Re: Secure 2.0 catch-up Roth 401K

Post by Alan S. »

Alan S. wrote: Mon Jul 17, 2023 12:19 pm
Eagle33 wrote: Sat Mar 18, 2023 9:15 pm
biker2035 wrote: Sat Mar 18, 2023 12:53 pm I am wondering if this new Act allows the match I get into my 401K, can I direct those funds to my workplace Roth 401k instead? Currently contribute to the 401k, but in the past contributed to the Roth 401k.
Starting in 2024, not 2023.
Or maybe in 2026! A very large group of interested organizations have requested the IRS to delay this provision and all of its many challenges for 2 more years.

s://www.asppa.org/news/where-we-are-roth-ca ... -provision
Yet another request for a 2 year extension to the 2024 effective year:

https://www.eric.org/wp-content/uploads ... -Final.pdf

I don't see how the IRS can avoid granting at least a 1 year delay. If they don't they will be under tremendous pressure to resolve all of the many issues with this provision.
Harri88
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Re: Secure 2.0 catch-up Roth 401K

Post by Harri88 »

cshell2 wrote: Tue Jul 18, 2023 8:59 pm
Harri88 wrote: Tue Jul 18, 2023 4:03 pm Question, if my catch-up contributions go into a Roth 401k. Is there any impact to contributions for my Roth IRA?
The only way I could see that happening is if you are near the limit to direct contribute to a Roth IRA and go over due to AGI increasing from 401K catch up switching to Roth. Otherwise, they are two separate things with separate limits. Contributing to a Roth 401K doesn't reduce what you can put in a Roth IRA.
Eagle33 wrote: Tue Jul 18, 2023 8:38 pm
Harri88 wrote: Tue Jul 18, 2023 4:03 pm Question, if my catch-up contributions go into a Roth 401k. Is there any impact to contributions for my Roth IRA?
IMHO, no.
Thank you for the answers. I am going to have to estimate to see if our AGI will push us over the Roth IRA limit now :annoyed
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Artsdoctor
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Re: Secure 2.0 catch-up Roth 401K

Post by Artsdoctor »

^ You can feel the exasperation oozing from the letter . . .
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