SIMPLE ROTH IRA

Hi
Do income limits apply to those who wish to contribute to a SIMPLE ROTH IRA?

Also, can a participant contribute to both a traditional SIMPLE and ROTH SIMPLE during the same year?



Most likely no income limits and participant could split the SIMPLE contributions between the two. However, with no sign of the needed IRS regulations I doubt that any IRA custodian has permitted such contributions in 2023, and the regs will not be in place when 2024 starts either. In the meantime, after 2 years participants can still convert their pre tax SIMPLE IRA balance to a Roth IRA.

thank youdo you  have an expecation for when the IRS regs will be in place?

No idea. Between Secure 1.0 and 2.0, the IRS is way behind the 8 ball. Of course, the legislative effective dates provided no or very little lead time for many of the provisions. 

  • Keep in mind, the Roth employee deferral and employer contribution SECURE Act 2.0 provisions are voluntary. An employer/plan is not required to amend the plan for those features.
  • Then considered that the IRS recently issued guidance delaying the start date for mandatory Roth catch-up contributions for higher income individuals. From 1/1/2023 – > 1/1/2026. It is anyone’s guess when the Roth employee deferral and employer contribution features might be available in SIMPLE IRA plans.
  • I’ll go out in a limb and suggest IRS SIMPLE IRA guidance with the issue of new Forms 5304-SIMPLE and 5305-SIMPLE would likely be needed by July or August of 2024. To allow 2025 SIMPLE IRA notice/enrollment packages to be sent out by employers by the required 11/02/24 date.
  • We are still waiting for IRS guidance and final regulations  for some provisions in the original SECURE Act and it had FAR fewer retirement plan provisions.
  • I actually have a lot of empathy for the burden Congress has dumped on the IRS. I never thought I would be saying that or this; “We should be patient.”
  • My recent experience is the vast majority of IRS employees are doing the best they can.

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