by Prof. Robert Bloink and Prof. William H. Byrnes
The IRS has now released long-awaited proposed regulations offering some clarifications on the new retirement plan contribution provisions enacted by the SECURE Act 2.0. These proposed regulations offer some clarity with respect to the new catch-up provisions—especially with respect to the new rules governing mandatory Roth catch-up contributions for higher-income employees. While the regulations do offer clarifications, they also leave some questions unanswered—and they demonstrate that all business owners should pay close attention to the details and watch for continuing guidance as they implement their retirement savings options.
SECURE 2.0 Catch-Up Contribution Changes: Background