How After-Tax Contributions Become Tax-Free Retirement Income

A ruling clarifying the rollover of after-tax contributions gives serious savers the opportunity to increase tax-free assets
A ruling clarifying the rollover of after-tax contributions gives serious savers the opportunity to increase tax-free assets.

For many years, after-tax contributions to retirement plans were like the seventh batter on a professional baseball team. Weaker tax incentives meant after-tax contributions didn’t offer the same performance potential as before-tax or Roth contributions, but they still were good enough to earn a place in the lineup.

IRS ruling changes the game

That changed in late-2014, when a ruling[1] from the Internal Revenue Service (IRS) bumped after-tax contributions up in the batting order. The new rules gave participants the option to:

  1. Rollover after-tax contributions into Roth IRAs when participants retire or leave their companies; or
  2. Convert after-tax contributions to Roth plan contributions in-plan, as long as plan documents allow it.

Since limits on after-tax contributions are far more generous than those on pre-tax or Roth contributions, or Roth IRAs, these changes give serious savers opportunities to build sizeable Roth accounts.

Roth IRA contribution limits

The trouble with Roth IRAs, which offer a great way to save for retirement, is that there are contribution and income limits. For 2016, the maximum annual contribution to a Roth IRA is $5,500 ($6,500 for people who are age 50 or older). However, many Americans cannot contribute to a Roth IRA. For example,[2]

  • A person who files taxes as a single and earns $132,000 or more each year cannot save in a Roth IRA.
  • A couple that files taxes jointly and earns $194,000 or more each year cannot save in a Roth IRA.

There is a way for everyone—regardless of income level—to save more in Roth advantaged accounts. It involves making after-tax contributions to employer-sponsored retirement plans.

Roth opportunities through employer-sponsored retirement plans

If a 401(k), 403(b), or 457(b) plan allows it, employees can make Roth contributions and after-tax contributions to their plan accounts. Generally, there are no income limits on plan contributions. However, there are contribution limits.

Traditional and Roth 401(k) plan contributions together cannot exceed $18,000 in 2016 ($24,000 for savers who are age 50 or older).[3] Despite this limit, plan participants can still accumulate significant tax-free savings for retirement.

For instance, imagine a fictional participant named Donna contributes the maximum to a Roth plan account from age 40 to age 67. She makes catch-up contributions beginning at age 50, and earns 5% on average, each year. At retirement, Donna will have about $1.3 million in Roth savings to generate income. If she applies the 4% Rule, she can withdraw about $52,000 each year, tax-free.[4],[5]

It should be noted that any tax-deferred earnings must rollover into a Traditional IRA or they may be taxed as ordinary income. When distributions are taken from a Traditional IRA, generally, they are taxed as ordinary income.[6]

In-plan Roth conversions allow rollover of earnings

Another beneficial option would be for Donna to contribute the maximum to both her Roth and after-tax plan accounts and complete an in-plan conversion each year. An in-plan Roth rollover may include elective deferrals, matching contributions (including qualified matching contributions), non-elective contributions (including qualified non-elective contributions), rollover contributions, after-tax employee contributions, and earnings on the above contributions.[7]

Of course, a plan’s documents must allow Roth contributions, after-tax contributions, and in-plan conversions for highly compensated participants to adopt this strategy.[8]

Summary

The 2014 IRS ruling clarifying the rollover of after-tax contributions into Roth accounts gives serious savers the opportunity to significantly increase the amount of tax-free assets they can accumulate, as well as the amount of tax-free retirement income they have the potential to generate throughout retirement. Plan participants should work with their tax or financial advisors to determine if it’s a strategy that’s right for them.


[1] Internal Revenue Service. “Guidance on Allocation of After Tax Amounts to Rollovers.” Notice 2014-54. www.irs.gov cited May 2016.

[2] Internal Revenue Service [https://www.irs.gov/Retirement-Plans/Plan-Participant,-Employee/Amount-of-Roth-IRA-Contributions-That-You-Can-Make-for-2016] [3] Internal Revenue Service [https://www.irs.gov/Retirement-Plans/Retirement-Plans-FAQs-on-Designated-Roth-Accounts] [4] William P. Bengen. “Determining Withdrawal Rates Using Historical Data.” Journal of Financial Planning. October 1994. [http://www.retailinvestor.org/pdf/Bengen1.pdf ] [5] The 4% Rule assumes that it’s safe to withdraw 4% of savings each year during retirement if the savings needs to last for 30 years. There is some debate about whether 4% is a safe withdrawal rate over 30 years of retirement. Some experts suggest retirees should take a smaller percentage of savings each year.

[6] Internal Revenue Service, “Rollovers of After-Tax Contributions in Retirement Plans.” www.irs.gov cited May 2016. [https://www.irs.gov/Retirement-Plans/Rollovers-of-After-Tax-Contributions-in-Retirement-Plans] [7] Internal Revenue Service, “Retirement Plans FAQs on Designated Roth Accounts,” www.irs.gov cited May 2016. [https://www.irs.gov/Retirement-Plans/Retirement-Plans-FAQs-on-Designated-Roth-Accounts#irr] [8] Ibid.

Terry Dunne
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Before retirement, Terry Dunne was the senior vice president and managing director of Retirement Services at Millennium Trust Company, LLC. Mr. Dunne has over 40 years of consulting experience in the financial services industry. He has written extensively on retirement planning, industry trends, technology, and legislation. Millennium Trust performs the duties of a directed custodian, and as such does not sell investments or provide investment, legal or tax advice.

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