IRS Notice 2009-68

Per previous postings, employers are not recognizing IRS Notice
2009-68 yet. As such, the distribution to the trust account will be
all after tax. Is that still the case?

Note: IRS Notice 2009-68 would require prorating all distributions
between pre and after tax.



There has been no further IRS guidance on 2009-68 and it’s implications.

However, would need more details about the specific distribution you refer to including the plan provisions and sub accounts that may exist in the plan.

What type of plan and is the participant still working for employer or separated?
This is not a rollover, just a fully taxable distribution?



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