IRS Pub 4530 Wrong?
IRS Pub 4530 (Rev.12-2017) regarding designated Roth accounts. The publication provides an overview of designated Roth accounts, but it appears one of the Q&As is wrong.
Q. Who is eligible to make an in-plan Roth rollover?
A. Participants, surviving spouse beneficiaries and alternate payees (who are current or former spouses)
are eligible to make an in-plan Roth rollover in a plan offering these rollovers. However, the individual
making the in-plan Roth rollover must be eligible for a distribution from the non-Roth account.
Doesn’t the American Taxpayer Relief Act of 2012 allow for in-plan rollovers even if the participant is not eligible for a distribution?
Permalink Submitted by Alan - IRA critic on Thu, 2018-01-11 23:51
You are correct. Q 2 of Notice 2013-74 addresses IRRs of otherwise non distributable amounts (ONAs). 4530 is a new Pub, so this is not an oversight in updating a prior Pub. Some plans may allow IRRs of ODAs but not ONAs, but the Pub appears incorrect.