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Retirement Planning > Saving for Retirement

For High Earners, Roth Catch-Up Contributions Are Tricky

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What You Need to Know

  • Such contributions are an important savings tool for those who can afford them, but their management is getting more complex.
  • Under Secure Act 2.0, those making more than the threshold will soon have to direct such contributions to Roth accounts.
  • A recent analysis shows relatively few workers are likely to be affected, but many employers will have to make changes.

The provision of the Secure 2.0 Act requiring people earning more than $145,000 in annual FICA wages to direct any retirement plan catch-up contributions to Roth-style accounts is likely to affect only a small percentage of the saver population.

Nonetheless, the Roth requirement will be potentially disruptive for employers and highly compensated workers when it eventually kicks in.

This is according to an analysis published in March by the Employee Benefit Research Institute. The topline finding shows that, of all the participants ages 50 or older earning more than $145,000, only 21% made contributions of more than $19,500 to their retirement plan in 2021 — meaning they would have found themselves subject to the Roth requirement.

As EBRI’s report explains, these participants make up a small share of all participants, but roughly one-half of all plans would be affected by this Roth requirement. As of 2021, the catch-up contribution limit was $6,500, and with inflation, this has climbed to $7,500.

Although the dataset used to analyze the high-income Roth catch-up rule includes only public retirement plans run by schools, governments and other such institutions, the conclusions can be expected to hold in the private sector.

In fact, the effects of the all-Roth catch-up requirement for high earners may be even more widespread in the private sector, given the historic (and widening) pay gap that has long existed between public and private work.

“While the percentage of public-sector participants affected by this mandatory provision is relatively low, the percentage of the public-sector plan sponsors in the database impacted is much higher at 55%, as these participants are dispersed across many plans,” the authors explain.

“In other words, one in every two plan sponsors may be required to make plan administration changes as a result of this provision,” they note.

More Key Findings, Details

In addition to quantifying the number of people and employers potentially to be affected by this rule — which has been delayed until 2026 under IRS guidance — the EBRI researchers also looked at the retirement plan balances of this older, higher-earning group.

The results show a wide spectrum of savings levels, suggesting a varying degree of commitment to workplace retirement savings among the group.

Specifically, among those older than 50 making more than $145,000 as of 2021, some 32% of workers had account balances of $200,000 or less.

Another 25% carried balances between $200,000 and $400,000; 16% carried balances between $400,001 and $600,000; 11% carried balances between $600,001 and $800,000; 7% carried balances between $801,000 and $1 million; and 9% carried balances over $1 million.

Overall, EBRI’s data shows, some 57% of the participants had account balances of $400,000 or less, meaning they will likely have an incentive to direct money toward catch-up contributions in the years ahead — assuming they are able.

Such savers, EBRI notes, may benefit from the substantial increase in catch-up contribution limits created by Secure 2.0 for people between ages 60 and 63, but they will also have to grapple with splitting their contributions across tax-deferred and pre-tax accounts.

Currently and as noted, retirement plan participants 50 and older can contribute an additional $7,500 to their retirement plan. Beginning Jan. 1, catch-up limits for participants ages 60 to 63 will increase to the greater of $10,000 or 50% more than the regular limit for 2025.

A Warning to the Wise

Beyond the potential disruption to individual savers, retirement planning and tax experts have warned, the catch-up contribution administration effort is about to get a lot more complex for employers and retirement plan providers.

And the stakes are high, given that uncorrected errors can trigger big penalties and tax bills — and potentially the disqualification of the retirement plan itself.

To begin with, the $145,000 limit is a new limit — meaning that it is not related to the existing definitions for highly compensated employees used for such key purposes as nondiscrimination testing. This could add confusion to an already complicated and jargon-laden administration effort.

The income test for the Roth requirement also does not treat all forms of compensation the same. As the law is written, the $145,000 amount is tied to W-2 income.

Thus, for example, if an S corporation owner takes $130,000 in “compensation” but also receives additional profits from the S corporation, the owner will not have crossed the $145,000 threshold to trigger the “Rothification” rule.

Similarly, the new Roth contribution rule would not apply for sole proprietors, partners in partnerships or LLC members who are taxed as sole proprietors. That’s because these taxpayers are considered self-employed and, by definition, do not receive W-2 compensation.

The bottom line, legal experts agree, is that catch-up contributions remain an important retirement planning tool for those who can afford them, but caution is warranted as the rules change and evolve.

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