Life and Death Planning for Retirement Benefits

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108 Life and Death Planning for Retirement Benefits
This does not tell you what constitutes a “distribution” (see . Nor does it
tell you how much of a particular distribution constitutes after-tax or pretax money; for that, see
instead.
Once you have identified a particular “distribution” made from the participant’s account,
and you have determined how much of that distribution is after-tax money, this tells you
what happens to the pre- and after-tax money included in that distribution when the distribution is
paid to different “destinations,” or (following the distribution) is partly rolled over:
“B” explains what happens when a single distribution is sent, via direct rollover, partly to
a Roth IRA and partly to a traditional IRA.
“C” explains the tax treatment of a QRP distribution that is partly paid outright to the
participant and partly sent via direct rollover to an IRA.
“D” explains the tax treatment of a QRP distribution that is paid outright to the participant
then partly rolled over by the participant, within 60 days, to one or more IRA(s).
“E” explains the effect of having a distribution sent, via direct rollover, entirely into
multiple traditional IRAs or multiple Roth IRAs.
“F” explains how this section applies to beneficiaries who have inherited QRPs.
“G” discusses the effective date of Notice 2014-54 and the options for participants who
took QRP distributions between 9/28/09 (issuance of Notice 2009-68) and 10/6/14 (issuance of
Notice 2014-54).
This book does not cover direct rollovers from one QRP to another. See instead Notice
2014-54, Examples 2 and 3.
The rules discussed in this also apply to distributions and rollovers from 403(b)
plan accounts and governmental 457(b) plan accounts that contain after-tax money. Notice 2014-
54, “Purpose,” “Background.”
However, these rules do not apply to:
 Partial rollovers and split distributions from a Designated Roth Account (DRAC); see
instead of this section.
 Distributions that are in the form of annuities. If the participant’s plan account has been
“annuitized,” that is, converted from an individual account plan (also called a defined
contribution plan) into a true annuity (stream of fixed payments for the life or lives of one
or more individual(s) or for a term of years), different rules apply. Notice 2014-54,
“Background.”
B. Part direct rollover to Roth IRA, part direct rollover to traditional IRA
If the participant instructs the plan administrator to transmit part of his distribution to a
Roth IRA and part to a traditional IRA, the participant should also instruct the plan administrator
which IRA should receive the after-tax money. The participant should tell the plan administrator
to transfer the after-tax money to a Roth IRA. The pretax money should be directed to a traditional
IRA (assuming the participant wants to continue deferring tax on it). This enables a participant
who is retiring (or for some other reason receiving a distribution from a QRP) to do a “tax-free
Roth conversion” of the after-tax money in his QRP account, while continuing to defer tax on the
pretax money in his account. See Notice 2014-54, Examples 1 and 4.
This option to “separate the cream from the coffee” when taking a QRP (or 403(b), or
governmental 457) distribution that includes after-tax money, by doing a tax-free Roth conversion