The IRS has recently released the final regulations with regard to the ROTH inhabilaries of Secure Act 2.0 (ie the new rule For people whose wages in the previous year of the employer in question had surpassed a certain threshold, any catch -up contributions must be made to the plan sponsored by the employer this year as Roth instead of postponed tax).
The new regulations clarify, among other things, that “the applicability of Roth’s catch-up requirement on a participant is based on last year’s FICA wage, reported in box 3 of Form W-2 for the participant.” The most important points are: independent income does not count (that is, the requirement will not activate), nor would wages earned by a government officer who is not subject to tax on social security.
The regulations are generally applicable from 2027.
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