Before you roll overWhat a retirement account costs, and what it forbids

Can I send the after-tax part of my 401(k) to a Roth IRA and the pretax part to a traditional IRA?


Summary

Yes, if both parts leave the plan in one distribution and you tell the plan administrator how to split the pretax money before the direct rollovers are made. The split works only on what comes out: a partial distribution from an account that holds both kinds of money carries a proportional share of each, so every after-tax dollar reaches the Roth IRA only when the whole balance is distributed.

Why you can't take only the after-tax money

The IRS example uses a $100,000 balance made up of $80,000 pretax and $20,000 after-tax. Ask for $50,000 and you get $40,000 pretax and $10,000 after-tax, the same 80/20 mix as the account, and the other $10,000 of after-tax money stays in the plan with the remaining $40,000 pretax. The IRS answers the question directly in its FAQ: "No, you can't take a distribution of only the after-tax amounts and leave the rest in the plan." Notice 2014-54 did not change that.

What Notice 2014-54 changed

Before 2014, sending pretax money to one place and after-tax money to another meant a 60-day rollover, and the pretax portion was hit with the mandatory 20% withholding along the way. The notice fixed that by treating all payments scheduled at the same time as a single distribution, whether they go to one destination or several. Pretax dollars are assigned first to whatever is directly rolled over. When the direct rollovers go to two or more places, you choose how the pretax amount is split among them, and the notice requires you to inform the plan administrator of that choice before the rollovers are made.

Take the full $100,000 from the example above. The IRS says you may request:

The $10,000 paid to you is not taxed, because those dollars were taxed before they went into the plan. Notice 2014-54 has a version with no cash payment: $80,000 directly rolled to a traditional IRA and $20,000 to a Roth IRA, with all of the pretax amount allocated to the traditional IRA so the Roth IRA receives only after-tax dollars.

Earnings count as pretax

Earnings on after-tax contributions are treated as pretax amounts. For example, if $20,000 of contributions has grown to $23,000, only the $20,000 can go to the Roth IRA without tax; the $3,000 of earnings is pretax and can go to the traditional IRA, where it isn't taxed until you take it out. What happens if earnings go into the Roth IRA anyway is covered in the guide to the tax on a Roth IRA rollover.

After-tax contributions are not Roth 401(k) contributions. The notice's examples assume a plan with no designated Roth account, and money in a Roth 401(k) follows the separate rules in the guide to rolling a Roth 401(k) into a Roth IRA.

When the receiving plan can't take after-tax money

A new employer's plan has to account for after-tax contributions separately before it can accept them. In one of the notice's examples, the same $80,000 pretax and $20,000 after-tax account sends $82,000 in direct rollovers: $50,000 to a new plan that doesn't keep that separate account, and $32,000 to an IRA. Because $82,000 is $2,000 more than the pretax amount, the rollovers include $2,000 of after-tax money, and that $2,000 cannot go to the plan. The whole $50,000 going to the plan must be pretax, which leaves the IRA with $30,000 pretax and the $2,000 after-tax. Each payment in a split like this may also come with its own Form 1099-R.

Sources

Written by Kaz, an independent publisher.
Corrections: the contact form.

Open the fee calculator