Notice 2023-62: Guidance on new Roth catch-up requirement, including administrative transition period
Comments must be submitted in writing on or before October 24, 2023.
Comments must be submitted in writing on or before October 24, 2023.
The IRS today released an advance version of Notice 2023-62 [PDF 142 KB] providing guidance with respect to section 603 of Division T of the SECURE Act 2.0 (signed into law on December 29, 2022, as part of the “Consolidated Appropriations Act of 2023” (H.R. 2617)).
Under that provision, 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.
As explained in a related IRS release—IR-2023-155—Notice 2023-62 announces 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 also clarified that plan participants who are age 50 and over can continue to make catch up contributions after 2023, regardless of income.
Comments on the matters discussed in the notice are invited and must be submitted in writing on or before October 24, 2023.
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