AICPA seeks further clarity on Roth rules

July 16, 2025

The AICPA has requested further guidance from the Treasury and the IRS regarding catch-up contributions designated as Roth contributions under Section 603 of the SECURE 2.0 Act.

In a letter dated Tuesday, July 1, the AICPA highlighted the need for clear regulations to ensure compliance with the Roth mandate, which affects employees eligible for catch-up contributions based on income thresholds.

“Post-SECURE 2.0, employers and plan administrators will need clear guidance to ensure compliance of the law regarding Roth-mandated catch-up contributions,” Kristin Esposito, director of Tax Policy & Advocacy at the AICPA, said.

The AICPA also recommended creating a safe harbor for using Form W-2 information to determine employee eligibility for the Roth mandate and asked for clarification on the treatment of disregarded entities in this context. Learn more.

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