403b and SEP

Can someone have a 403(b) where he is maxing out his personal contribution ($19.5K) and receiving $10K from the organization in match/non-elective as well as a SEP set-up with separate 1099 consulting income from his side job?



Yes, except that the SEP contribution will be limited to 27,500.  Because a 403b must be treated as the participant’s plan the total of the 403b contributions and the SEP contribution cannot exceed the Sec 415c limit of 57,000.  (57000 less 403b 29,500 = 27,500). In other words, both plans are subject to a single 415c limit. This would not be the case if they had a 401k plan instead of the 403b.

To confirm, because the employer plan was a 403b and not, for example, a 401k, the SEP must be limited to the max (assuming max allowed) LESS the 403b contributions.  Correct?  There is no dual-plan, separate employer exception as some advise is permitted with a 401k and SEP, or similar?

Yes, that is correct. There is no exception to the 415c limit applying to the total contributions to both plans since they are both treated as being maintained by a single employer.

  • If the individual’s Roth MAGI prevents them from making direct Roth IRA contributions. They could make non-deductible traditional IRA contributions and do a Roth conversion. This is the so-called Backdoor Roth. In a year with any Roth conversion, any pre-tax balances in all traditional, SEP and SIMPLE IRAs account on 12/31 of that year are subject to to pro-rata taxation.
  • If the individual wished to use the Backdoor Roth, it would be advisible to have no SEP IRA balance on 12/31. This can be solved in different ways.
  • If this is for 2020 tax year contributions, the individual can adopt, maintain and make employer contributions to a one-participant 401k instead of a SEP IRA. A 401k does not cause pro-rata taxation of a Backdoor Roth, but is still subject to the 403b annual addition limitation desribed by Alan above.
  • If this is for 2019 tax year contributions, it is too late for the individual to adopt a one-participant 401k. The individual can adopt and make 2019 tax year contributions to a SEP IRA by this year’s postponed tax filing deadline (07/15/20) including extensions (10/15/20). Then there are two options to rollover the SEP IRA by 12/31.
  • If the individual adopted a one-participant 401k that accepts IRA rollovers (not Vanguard). They could rollover the SEP IRA to the one-participant 401k.
  • If the individual’s 403b accepts IRA rollovers, they could rollover the SEP IRA to the 403b

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