in service distribution of Roth 401k to Roth IRA

Submitted by Charles Duncan on Tue, 2015-05-19 01:27

Besides non Roth after tax 401k contributions, does the Sept 2014 revenue ruling allow Roth 401k contributions be split off from employer match and other pretax contributions and rolled into a Roth IRA? i.e., I have 300k in after tax Roth 401k contributions, 100k of Roth 401k gains on the 300k, 60k pretax employer match contributions and 20k of gains on the employer match portion. Can I roll just the 400k Roth 401k balances into my Roth IRA as an in service distribution or must I meet the age 59 1/2 requirement (I meet the five year active participant requirement)? obviously this assumes the plan allows it



Submitted by Alan - IRA critic on Tue, 2015-05-19 02:07

  • Notice 2014-54 is not applicable to your situation. The Roth 401k can all be rolled to a Roth IRA if your balance is distributable.  Amounts from Roth elective deferrals are not eligible for rollover prior to age 59.5. But other amounts may be eligible for rollover according to the plan provisions.
  • Your 300k balance could not have been contributed in the few years of the Roth 401k. The only way you could have this much basis in your Roth 401k would be if you did a sizeable in plan Roth rollover (IRR). Did you do an IRR, and if your Roth 401k basis is correct due to an IRR, it must be determined if your IRR was done with distributable amounts or otherwise non distributable amounts. In other words, more detail is needed.


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