Web Reference: Q: What is a deemed Roth election? A: The final regulations retain the ability for a plan to adopt a deemed Roth election. Doing so allows a plan to convert a participant’s pre-tax catch-up election to a Roth contribution for participants subject to the requirement. This table shows the differences between traditional IRAs (not including traditional SIMPLE IRAs) and Roth IRAs (not including Roth SIMPLE IRAs). Answers in the middle column apply to traditional IRAs. In early fall 2025, Vanguard will provide plan sponsors with a template to report all Roth catch-up required participants on an annual basis. The Roth catch-up required participant population will need to be identified via a new FICA wage indicator.
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