On December 20, 2023, the IRS issued Notice 2024-02, which includes guidance on 12 provisions of the SECURE 2.0 legislation. The December 27 Slott Report, written by Sarah Brenner, has a summary of the guidance on several of those provisions. This article will address the guidance on Roth employer contributions to 401(k) and other plans.
On December 20, the IRS gave us the holiday gift of some guidance on a few provisions from the SECURE 2.0 Act. Notice 2024-02 is in a question-and-answer format and provides much needed clarification on SECURE 2.0 provisions, some of which are already in effect, and others which will come online in just a few short days in 2024.
If the Grinch and Bad Santa both passed their FINRA Series 7 exam and decided to open an investment advisory firm, I’m pretty sure they would combine forces to intentionally deliver some of the WORST financial advice possible. Here are some of their truly terrible, hideously horrible, good-for-nothing planning ideas:
Of the 92 provisions in the SECURE 2.0 legislation, signed into law last December, by far the most challenging is section 327. Section 327 changes the distribution rules for spouse beneficiaries of IRA (and workplace plan) account holders and is effective January 1, 2024.
You may not be familiar with the tax code’s “same-property rule” that applies to IRA-to-IRA (and Roth IRA-to-Roth IRA) rollovers. The rule requires that the property received in an IRA distribution must be the same property that is rolled over. If you receive cash, you have to roll over cash.
The August 28, 2023 Slott Report summarized IRS Notice 2023-62, where the IRS delayed the effective date of the SECURE 2.0 rule requiring catch-up contributions by higher-paid older employees to be made on a Roth basis.
Last Friday afternoon (August 25, 2023), the IRS gave employer plans two more years to comply with the controversial SECURE 2.0 rule requiring “catch-up contributions” for high-paid employees to be made on a Roth basis. The effective date of the rule was postponed from January 1, 2024 to January 1, 2026. The delay is set forth in IRS Notice 2023-62.
If you are subject to required minimum distributions (RMDs) and have annuitized part of your IRA, a recent law change could drastically reduce your RMDs. But, without IRS guidance, it may be difficult to take advantage of that change.
On July 17, we reported that the IRS had issued required minimum distribution (RMD) relief in two situations. First, the Service excused 2023 RMDs for certain IRA (and plan) beneficiaries subject to the 10-year payout period. Second, it extended the 60-day rollover deadline for retirement account owners born in 1951 who erroneously received distributions in 2023 that weren’t necessary because their first RMD year had been delayed from 2023 to 2024 under SECURE 2.0.
If you’re an IRA beneficiary subject to the 10-year payout period and would have had a 2023 RMD (required minimum distribution), you’re in luck. In Notice 2023-54 issued last Friday (July 14), the IRS said it would excuse those RMDs. The IRS also said it would extend the 60-day rollover deadline for IRA (and plan) account owners born in 1951 who received distributions in 2023 that weren’t necessary because of the SECURE 2.0 change that delayed their first RMD year from 2023 to 2024.
