By Dr. Jim Dahle, WCI Founder
I first wrote about multiple 401(k) accounts back in 2013 in a post entitled Beating the $51K Limit (for which I am still eternally grateful to Mike Piper for the pearl that grew into that post). Well, the $51K limit has since grown into the $70K limit in 2025 thanks to inflation, but all the same principles still apply.
I get tons of questions on multiple employer 401(k)s in our Forum, Podcast, Facebook, and Reddit groups, in the comments sections of the posts on this site, and by email. Heck, this post already has over 1,000 comments! Mostly, I wrote this post so I could copy and paste its URL instead of typing the same old stuff over and over again. (Come to think of it, that was the motivation for starting this site in the first place.)
Can You Have Multiple 401(k)s?
Here's the deal. Many physicians work for multiple employers or work as an employee and either an independent contractor or a consultant. Many others have a side job of another type. Their incomes are far higher than they require for their current spending needs, but they're behind on their savings or otherwise have a desire to maximize the amount of money they can put into retirement accounts, especially tax-deferred retirement accounts.
Obviously, these types of accounts minimize tax, maximize returns, increase asset protection, and facilitate estate planning. Who wouldn't want to get more money into them? However, most of these doctors are surprised to learn that they can have more than one 401(k). That's right,
YOU CAN HAVE MORE THAN ONE 401(K)!
Okay, now that I've got that out of my system, let's make a list of the 7 governing rules for using more than one 401(k):
What to Do with Multiple 401(k) Accounts – Multiple 401(k) Rules
Rule #1 – One Employee Contribution Total
In 2025 the IRS only allows you to make a total of $23,500 ($31,000 if 50 or over) worth of “employee contributions” to all of your 401(k)s (or 403(b)s) no matter how many unrelated employers you have. If you have access to two 401(k)s, you can split this up, but the total must be $23.5K ($31K if over 50) or less.
Rule #2 – $70K per Unrelated Employer
The IRS also only allows you and your employer (which might also be you) to put a total of $70,000 for 2025 ($77,500 if 50+) per year into a 401(k). This includes the employee contribution, any match from the employer, and any employer contributions. This is the same limit for a SEP-IRA (if <50) which is technically all employer contributions. However, unlike rule # 1, this limit applies to each unrelated employer separately.
“Unrelated employers” means that the businesses doing the employing are not a “controlled group.” There are two types of controlled groups:
- “Parent-Subsidiary” Group
This is when a parent business (corporation, sole proprietor, LLC, partnership, etc.) owns 80%+ of another business. - “Brother-Sister” Group
This is where 5 or fewer individuals, estates, or trusts own a controlling interest (again, 80%+) of two different businesses.
So if the two businesses you are involved in aren't a controlled group, and they each have a 401(k), (or a 401(k) and a SEP-IRA) you get two $70K limits. Pretty cool, huh? There are several common examples where this could apply to a physician:
Multiple 401(k) – Example #1
A 40-year-old single physician is an employee of two completely unrelated hospitals. The first pays her $200K per year and matches 100% of her first $5K put into the 401(k). It also offers her a 457. The second pays her $100K per year and matches 50% of the first $7K she puts into her 401(k). What retirement accounts should this physician use in order to maximize her contributions in 2020?
- Hospital 1 401(k): At least $5K (plus the $5K match) = $10K
- Hospital 1 457: $23.5K
- Hospital 2 401(k): At least $7K (plus the $3,500 match) = $10,500
- Plus another $11.5K into either hospital's 401(k) (pick the one with the better investments)
- Plus $7,000 into a Backdoor Roth IRA
- Total: $62,500
Multiple 401(k) – Example #2
A 40-year-old married physician whose spouse doesn't work is a partner in a 100 doctor partnership which offers a 401(k)/Profit-sharing plan in which he can “self-match” up to the $70K limit. The partnership also offers a defined benefit/cash balance plan with a $30K limit. He makes $300K practicing medicine. He is also the sole owner of a website on the side that makes $300K per year and has its own individual 401(k). Both 401(k)s offer a Roth option. What is the maximum amount he can put into Roth accounts in any given year without doing a conversion of tax-deferred or after-tax dollars?
- Partnership 401(k)/PSP: $70K, of which $23.5K can be Roth*
- Partnership DB/CBP: $30K, of which $0K can be Roth
- Website Individual 401(k): $70K, of which $23.5K could be Roth* if none of the Partnership 401(k) money represents an “employee contribution”. Otherwise, $0K Roth.
- Personal Backdoor Roth IRA: $7,000
- Spousal Backdoor Roth IRA: $7,000
- HSA: $8,550
- Total: $192,550 of which $37.5K can be Roth*
*Note that Secure Act 2.0 has made some changes which will allow the possibility of Roth matching contributions starting in 2023.
Multiple 401(k) – Example #3
This 52-year-old married physician (spouse doesn't work) is an employee of a hospital where she is paid $200K. She has a 401(k) with a set $20K employer profit-sharing contribution (not a match) and the hospital pays most of the premiums on a non-high-deductible health plan. She moonlights across town as an independent contractor and is paid on a 1099, where she earns $100K and has opened up an individual 401(k). The hospital 401(k) has terrible investments and high fees. How should she allocate her retirement savings in order to best use these options?
- Hospital 401(k): $20K employer contribution
- Individual 401(k): $31K employee contribution (50+) + 20% * $100K = $20K employer contribution = $51K (technically slightly less due to Rule # 5 below)
- Personal Backdoor Roth IRA: $8,000 (50+)
- Spousal Backdoor Roth IRA: $8,000 (50+)
- Total: $87K
Multiple 401(k) – Example #4
A 40-year-old single physician is in a business partnership with one other physician and they have several employees. Due to hassles and the costs of their employees, they have opted to use a SIMPLE 401(k) for their practice. He makes $200K. He also does some consulting work on his own as a sole proprietorship where he is paid on a 1099, about $50K per year. He and his physician business partner recently opened up another business where they sell a medical device. They are the only owners of both the practice and of the corporation that sells the device (which has no employees). He makes another $50K from this company of which $25K is salary and $25K is a “distribution” from the S Corp. What kind of retirement set-up should this physician do?
- Practice SIMPLE IRA: $16,500 employee contribution plus $6K (3% of salary) employer contribution: $22,500
- Unfortunately, these three entities are part of a “controlled group”, so he cannot have a separate retirement plan for either of the other two entities that ignore the employees in the practice. The presence of a SIMPLE IRA also makes it tough to use a Backdoor Roth IRA due to the pro-rata rule.
- Total: $22,500
Rule #3 – Employer Contributions Are 20% of “Net Earnings from Self-Employment”
When calculating the employer contribution for a SEP-IRA or an Individual 401(k), you use your “net earnings from self-employment”. This includes any amount used for an employee contribution, but excludes the amount used for S Corp distributions (those aren't “earned income” and so can't be used for retirement account contributions) and the amount used for the employer half of the payroll taxes (same as the self-employment tax deduction).
The employer contribution in an individual 401(k) and a SEP-IRA is exactly the same (for those under 50), but since you can also make an employee contribution into an individual 401(k) (and 401(k) money isn't included in the backdoor Roth pro-rata calculation), a 401(k) is generally the better option for the self-employed, even if it is slightly more complicated to open (and must be opened in the calendar year rather than before tax day of the next year). The possibility of a Roth SEP IRA starting in 2023 could provide another way around this rule.
Note that an employee owner of an S Corp is limited to 25% of W-2 compensation as an employer contribution.
Rule #4 – You Only Get One SEP, SIMPLE, or 401(k) per Unrelated Employer per Year
Each unrelated employer should only have one of these three types of accounts for each tax year. You can technically have more than one, but they share a combined limit. However, you could open a SEP-IRA for your self-employment income in March 2025 for tax year 2024, and then open an individual 401(k) in June 2025 for tax year 2025 if you like. Remember that just because you are the sole owner of two separate businesses doesn't mean you get two different retirement accounts. Those businesses are a controlled group.
Rule #5 – These Rules Have Nothing to Do with 457s, IRAs, or HSAs
457(b)s, Backdoor Roth IRAs, and HSAs all have their own separate limits that have nothing to do with the limits for 401(k)s, 403(b)s, SEP-IRAs, and SIMPLE IRAs. Putting more into a Roth IRA doesn't mean you can't still max out your 401(k).
Rule #6 – Catch-Up Contributions Also Allow You to Beat the $66K Limit
Many accounts have catch-up contributions if you're old enough (usually 50 or older, but 55 or older for HSAs). Roth IRAs have a $1,000 catch-up, HSAs have a $1,000 catch-up, and 401(k)/403(b)s have a $7,500 catch up. That $7,500 catch-up is in addition to the $70K limit, so if you're over 50, you're self-employed with lots of income, and you make your full $31,000 employee contribution to your individual 401(k), the $70K limit becomes a $77,500K limit. Note that 457(b) catch-ups and 403(b) catch-ups work slightly differently.
If 401(k)s are so great, why just stop at one?
Rule #7 – 403(b)s Are Not 401(k)s
Many physicians have access to a 403(b) by working for a hospital or public entity. There is a unique rule for 403(b)s, however, which will prevent many doctors who use a 403(b) at their main job from maxing out an individual 401(k) on the side, at least if they own 50% or more of the company for which they have an individual 401(k) (and they probably do). It doesn't make much sense, but neither do many tax and retirement plan rules out there. Basically, your 403(b) at work, unlike a 401(k), is considered to be controlled by you. So you are stuck with the same 415c limit of $70K (see Chapter 3 at the link). So if you put $23.5K into your 403(b) at work, you are only allowed to put $70K-$23.5K=$46.5K into an individual 401(k).
My Accountant Doesn't Believe You
Obviously, having access to multiple 401(k)s is an unusual situation among Americans in general, even if it is quite common among doctors. As such, an unbelievable number of accountants (and especially their clients) have a misunderstanding of the rules noted above, particularly the one about having a separate $70K limit for each unrelated employer. However, taking a look at this article on IRS.Gov written in layman's language, you can see this is true:
Overall Limit on Contributions
Total annual contributions (annual additions) to all of your accounts in plans maintained by one employer (and any related employer) are limited. The limit applies to the total of:
- elective deferrals
- employer matching contributions
- employer nonelective contributions
- allocations of forfeitures
The annual additions paid to a participant’s account cannot exceed the lesser of
- 100% of the participant's compensation, or
There are separate, smaller limits for SIMPLE 401(k) plans.
If that's not enough for your accountant, you can simply go straight to the actual code sections in question, in this case, 415(c) (where the $66K limit comes from, originally $40K). Be sure to scroll through subsections (f) through (h) where the relevant examples are used:
(f) Combining of plans
(1) In general
For purposes of applying the limitations of subsections (b) and (c)—(A) all defined benefit plans (whether or not terminated) of an employer are to be treated as one defined benefit plan, and(B) all defined contribution plans (whether or not terminated) of an employer are to be treated as one defined contribution plan.
Note how it says all defined contribution plans OF AN EMPLOYER are to be treated as one plan. Section (g) reads similarly:
(g) Aggregation of plans
… the Secretary, in applying the provisions of this section to benefits or contributions under more than one plan maintained by the same employer, ….with respect to which the participant has the control required under section 414 (b) or (c)…shall…disqualify one or more…plans…until such benefits or contributions do not exceed the limitations contained in this section.
There’s something you haven’t considered that can I see in the scenarios posted. I don’t know if this was covered n the comments. In some cases you have a “spouse does not work” and the Dr owns a website/blog business. If you add the spouse as an owner of the web business, a couple of things happen.
1. The profit sharing contribution increases from 20% to 25%.
2. You can pay a salary to the spouse.
3. You can include a 25% match on the spouses salary to the solo 401k.
1. No. That’s not true.
2. Sure, you can do that. Typically you only do that with an S Corp. Another option is having the spouse not own but be an employee.
3. You could do a whole lot more than that. The spouse, like you, could do after-tax contributions to a solo 401(k) and put $66K into it with $66Kish of income.
You seem to be confusing the whole 20% and 25% thing. Think of it this way, at least for owners. It’s 20% if you count the contribution in the denominator. It’s 25% if you don’t.
For an S Corp, it’s 25% of what you pay yourself as a salary, so it could be an even smaller contribution for the same amount of profit+salary because you took the profit as a distribution.
For point 1, I was basing it off the rules for multi member LLCs. My understanding was multi member LLCs and partnerships could contribute at 25% while single member LLCs and sole proprietorships were limited to 20%. I’ve read a lot of info in a very short time. It’s possible I’m conflating topics though.
For your responses to 2 and 3, that’s exactly where I was going.
Anyway, I thought I’d suggest adding a similar type scenario (corrected for any mistakes I have in understanding) where the spouse is added to the web business to increase opportunities for adding to retirement savings. Updating the article could help people see there are more opportunities for saving even if one spouse doesn’t work.
This is great topic. I know you are focused on medicine but there is fantastic info on your site for other professionals. I found it very helpful as I look to start a side hustle with my wife.
Ahh….I see.
Remember that if the partnership is just you and your spouse you can still use a solo 401(k). But I do think you’re conflating topics.
The tricky thing about adding that sort of scenario is a lot of people want to add their spouse to their business but not actually have their spouse do anything in the business. That’s not actually okay with the IRS. I added my spouse to WCI many years ago when it was a sole proprietorship. But she was really doing stuff and now is working more on it than I am. Now it’s an S Corp for tax purposes.
Hello all, hoping for some advice/clarity on this topic:
I have a group practice but each individual doctor has their own s-corp PC that we bill for our own services. I am the sole employee of my own s-corp PC. I maximize my employee contribution, which then gets matched by my employer, and then I contribute up to the maximum $61k (for 2022)
I recently took the expert witness start up school for a side-gig. The course suggests forming an LLC to keep things separate from my normal doctoring services. With this LLC, if I can earn enough money from it, I was hoping I could have a second 401k where I could contribute up to 25% of my earned income, understanding that I won’t have any employee contribution since I already do that with my other 401k. Asked my accountant who told me the following: “The maximum 401(k) deferrals and retirement contributions are absolute regardless of how many entities that one has. You can see how there might be abuses otherwise, just set up enough companies and double, triple, quadruple your retirement contribution. If you go over the annual limits after combining all contribution there potentially are penalties for over funding.”
My questions are as follows:
1) Can I have another 401K for this side-gig?
2) Since this work is going to be relatively intermittent, I am not planning on taking a consistent “salary” every month, but rather taking draws once I have earned enough money after covering business expenses. Does the fact that I am doing intermittent draws affect my ability to have a second 401k? Specifically, is the amount that I can contribute to this second 401k based on the amount I actually draw in each year, or just based on the amount that is earned, even if I don’t draw it out?
3) If it’s not possible to have a second 401k, should I even bother with forming an LLC for medical expert work, or just have that income go to my current S-Corp?
I’m not 100% sure what you mean by a “group practice.” Is this a partnership where the partners are S Corps? Or are you all independent contractors who just happen to have some sort of call sharing relationship or something. If the first, your S Corp can’t have its own retirement plan. You all have to use the same partnership retirement plan. If the second, it will be a controlled group with your new expert witness side gig since you own 100% of both businesses.
Your accountant might be right that you can’t get another retirement plan because you own 100% of both businesses, but the statement made by the accountant as you have quoted it is not technically correct as this post outlines.
The fact that you are taking draws has no effect on your ability to use a solo 401(k) for that business. You pay taxes and can make retirement contributions based on business earnings, whether you take the money out of the business checking account or not.
You don’t need an LLC to open a solo 401(k), only a business and an EIN. I think I’d probably still form an LLC for this new business and keep its finances separate from those of my practice S Corp, even if I couldn’t use a second 401k for doing so.
Thank you for the reply. We have a partnership with a partnership retirement plan. The practice is a pass-through company that pays for overhead like rent, employee salaries, etc. and we have a 401k matching program for our employees. Each partner has their own S-Corp that we are the sole employee of that we bill for our own medical services, and then we each pay our share of overhead to the pass-through company from our S-Corp. So to answer your question, we all have the same partnership retirement plan. Does that mean that my S-Corp is not a controlled group with the new side-gig expert witness work and I can have a separate 401k, even though I own 100% of my own S-Corp?
I think either way I should probably form a separate LLC for this side-gig work, which is really the question I’m trying to answer now. I just wasn’t sure if it was worth it if I couldn’t do a second 401k, since I already get the benefit of business deductions and the $66k 401k contributions.
So in this case the employer is the practice, and individual S-corps are not relevant because of that. So as long as 1099 work is NOT billed through the main practice or through the S corp (which will result in an affiliated service group) it sounds like a solo 401k for outside 1099 income is a possibility. It sounds like the accountant is playing it safe, but not playing it correctly. So there are indeed 2 separate limits available, however, employee contribution is in common. Thus, for the solo 401k, if you can’t max it out with tax-deferred contribution, you can do MBR 401k (after-tax converted to Roth, up to the maximum limit), which is especially useful if your net 1099 income is low (~$60k or so). Thus you can contribute ~20% as tax-deferred, and the rest can be after-tax that should be converted to Roth.
I contribute to a *mandatory* 403b plan ~$20k, which was matched by my employer ~$20k. Because that plan is a mandatory plan, my employer says I can contribute to a second 403b voluntarily (pre-tax). I contributed to this second *voluntary* 403b another ~$20k.
I have a solo401k from doing locums. I know that employee contributions are the same across 403b or 401k, and employer contributions are also the same, because I am considered my own employer for a 403b (hence I can’t “double dip” as I would if I had two 401k plans). I know that the limit this year is $61k.
However, when calculating the amount left to contribute to my 401k, is it:
1. ~$1k, because the $20k+$20k+$20k=$60k?
2. ~$20k, because my employee “bucket” is ~$20k (either the mandatory contribution or the second contribution doesn’t count) + $20k employer=$40k?
3. ~$40k, because I only count the employer $20k contribution?
Thanks in advance! This has confused us greatly.
You sure that first one isn’t a 401(a)? Sure sounds like it. That would be a much more common set-up than two 403(b)s from the same employer.
403(b)s have two weird rules to be aware of. The first is that your 403(b) shares the same 415(c) (aka $66K total contribution in 2023) limit with your solo 401(k). The second is that a 401(a) and a 401(k) share the same 415(c) limit but a 401(a) and a 403(b) each have a separate 415(c) limit.
But let’s figure out what you actually have before answering your question definitively.
Yes, it’s definitely a 403b, and that’s what’s confused everyone, even my friend who’s a CPA for the IRS. Here’s a quote from our HR:
“The ORP (403b) is a employer mandatory retirement plan for state/public institutions of higher education. The TDA (403b) is an optional/voluntary contribution for state/public institutions of higher education. The ORP portion has a predefined percentage you contribute and the TDA as a cap set by the IRS based on age. There is a combined cap (employee%/employer% match/and employee voluntary) overall for 403b contributions to not exceed $61,000 if you are under age 50 and if you are over age 50, that cap is $67,500. Also there is a salary cap on the ORP contributions which is a maximum of $305,000 for 2022. The 457 has a different designation under the IRS guidelines and allows for employees to max out their contributions based on those guidelines.
I’m sure this doesn’t really explain it to the satisfaction of an accountant. All I can assure is that it is legal and doable. We have had folks doing this for the 25 years that I’ve been here (maxing out both 403b options). And the 457 piece was added at least 15 years ago and I’ve had several faculty members doing both with no issues.”
So, in HR’s explanation, they treat both 403b for a combined cap of $61k, but given that it’s a non-traditional setup, with mandatory and voluntary contributions, I am having confusion about how much I really can contribute to my solo401k, as I asked in the first post.
Weird, I know. Thanks in advance for your help.
I think HR is doing it correctly then. You get one shared $66K 415(c) cap for all of your 403(b)s and solo 401(k)s. Sorry.
So in answer to your question, it’s the first option. You can put in another $1K for 2022 (but $6K for 2023 since the 415(c) limit goes up to $66K for 2023.)
Not much benefit to you for a solo 401k. Stupid set-up by your employer hosed you.
Note that the 457(b) contribution limit is totally separate though, just like the IRA contribution limit.
Hi all,
Was hoping to get some help with maximum contributions between my solo 401K and 403b for 2022. My understanding is there is a $61,000 total bucket aggregate between these two accounts. I am primarily trying to calculate the mega backdoor Roth contribution to my solo 401K needed to fill up the entire $61,000 bucket. Please let me know if my math below checks out or if there is anything I’m overlooking.
403b:
Employee Salary Deferral – $20,500.00
Employer Match – $4,656.16
Employer Contribution – $13,206.24
Solo 401k:
Employer contribution deferral (profit sharing) – $14,700.00
Employer contribution mega backdoor Roth – $7,937.60
Thanks so much.
I assume you’re under 50.
But yea, that all adds up to $61K.
Thank you. Yes, I’m under 50.
Quick clarification question. Per your article, my understanding is there is a $61,000 total bucket aggregate limit between the 403b and solo 401K. Does the 403b Employer Match and 403b Employer contribution count towards the $61,000 total? Between the employer match and contribution, my employer put $17,862.4 into my 403b for 2022.
In other words, if the 403b Employer Match and Contribution does not count against the $61,000 total then I should be able to contribute $40,500 into my solo 401K before meeting the $61,000 limit ($20,500 employee deferral + $40,500 profit sharing).
I should note that the $17,862.4 employer match and contribution to my 403b isn’t listed on the W2 that I was issued so I’m not totally sure how the IRS would know that my employer provided this profit share to my 403b.
Yes.
I agree the IRS is unlikely to catch this. Doesn’t make it legal though.
This post is incredibly helpful! After spending a couple of hours on the phone with the custodian of my new job’s retirement plan and the IRS, I was starting to worry that I wouldn’t be able to get an answer to a question about maximum allowable contributions to a 401k with a private employer and a 403b with my new nonprofit employer.
I’m about to start a job at a nonprofit with a mandatory retirement plan in which employees must contribute 6.2% of their paycheck to a 403b, and the employer will match that with their own 6.2% contribution to the 403b. My former employer was a large private company with a 401k to which my employer and I collectively contributed a little over $64,000 in the first quarter of 2023, which is very close to the $66,000 maximum allowable retirement contribution for one employer this year. I wasn’t sure if participating in my new employer’s mandatory retirement plan would get me into trouble with the IRS, but it seems pretty clear from reading your post and associated IRS documentation that I’m okay to participate in it because these are totally separate employers, and I do not own/control more than 50% of the private company where I previously worked. Thank you for providing such helpful information!
Our pleasure.
Hello all, hoping for some advice/clarity on this topic.
Currently, I have income from:
– W2 through work (activity #1)
– consulting work as self-employed (activity #2)
– I opened an LLC for a business (activity #3)
Note that in my case, consulting via self-employment and business via LLC do not overlap. LLC has the simplest structure: a married couple’s single-member LLC. I bring most of income to the LLC. My spouse helps with the website and help me find new clients but does not bring earned income to LLC. There are no employees for our LLC. We are 50/50 equal partners with each other. And we are living in a community property state.
Also, currently, I do the following for my retirement plans:
– Max out 401k plan from work
– Contribute ~20% from self-employed income to Self trad 401k
I want to open a new Self trad 401k + Self roth 401k (for mega backdoor roth).
My questions:
1) Do I understand correctly that even though activities #2 and #3 are not related and I have split of ownereship 50/50 with my spouse for activity #3, my total limit for self 401k is $66k (for 2023) and I cannot have two self 401k plans with separate $66k limits for each?
2) Can I combine net income from activities #2 and #3 to calculate eligible contributions for self 401k? (I know that it should be 20% net income – SS taxes)
3) Can my spouse also open separate 401k and roth 401k and contribute up to her limits from LLC income as well for activity #3? Or has she earned income from the LLC to be eligible to contribute?
4) If I have several self 401k accounts and total funds exceed $250k do I need to file form 5500-EZ or should separate 5500-EZ forms be filed for each self 401k that exceeds the $250k limit?
What do you mean “don’t overlap”? You own both those businesses, right? Your sole proprietorship and your LLC. So you get ONE retirement account total for both of them since they’re related businesses. Nobody cares about “overlap”, they only care if they businesses are related due to common ownership.
You cannot open a new solo 401(k), sorry.
1. That’s correct. One solo 401(k) plus whatever your employer offers.
2. Yes.
3. You can use the same solo 401(k) since you’re married. No need for a separate one. She’ll have her own $66K total contribution limit for 2023.
4. Why do you have several? Combine them all into one. The requirement though is to file when the plan has more than $250K in it. Maintaining multiple plans is way more hassle than filing a 5500-EZ though.
If you have two separate 401k’s can i have. 50k 401k loan from each?
Yes.
I read the IRS code you are referencing and contribution totals are per individual per year and very clearly spelled out. Even though it does say ‘one employer’ and ‘individual employer’ a few times in the text (for an unknown reason) there is no logical extension in those statements that is being made that should there be another employer these limits would be duplicated, triplicated.
There are plenty of people with a multitude of jobs and they would have 3 or 4 or more times the limit contribution? Ran this by two accountants, both said nonsense.
Buyer beware.
I, and lots of other very smart people, disagree with your interpretation of the code and your two accountants. You’re going to need a better source than that for me to change my recommendation that one can max out multiple 401(k)s in the same year when those 401(k)s are at unrelated businesses.
I think there may be a confusion on the part of the accountants regarding the details, but also possibly regarding how you asked the question. For one thing, just because there is a second 415 limit doesn’t mean someone can actually take advantage of it. First, there aren’t too many W2 employees who have two or more 1000+ hour jobs that allow them to be eligible to participate in multiple plans (and often there may not even be another plan to participate in). I also suspect it is how the question was posed. If someone has 2+ sources of 1099 income, this constitutes a controlled group, so you will only get 1 limit even though technically you may have multiple employers via multiple entities. So your accountants may have answered that part assuming multiple related entities.
How do we know someone can get two or more separate limits? This is actually from IRS itself. Look up controlled/affiliated group rules. The whole set of rules is there to make sure that members of controlled/affiliated group are aggregated into a single employer to disallow having separate limits for each employer (and more importantly, to make sure that staff of all aggregated employers is covered by a plan). This is all the proof necessary because if there isn’t a controlled/affiliated group, you can indeed have as many limits as there are unrelated employers. If in doubt, ask an ERISA attorney, not a CPA.
Hi Jim & WCI community,
I hope this has not already been discussed, I read through the forum and couldn’t find any situation like this. I have 3 income streams as a physician.
1. w2 ~ 160K. large hospital system. 401k profit sharing as part of the benefits.
2. 1099 ~ 79K. contractor admin for midlevel oversight.
3. k1 ~ 280K. large national partnership group. active clinical work.
So, based off my limited understanding… my 401k contributions could be as follows.
1. profit sharing component is ~ $13K.
2. sole proprietor and contribute to individual 401k ~ $79*.2=$15.8K.
3. k1 contribution as employer and employee ~ $56K.
(not including any backdoor roth or spousal roth IRAs).
Total 1,2,3 = $84.8
Thanks for your thoughts.
Was there a question? I can’t tell where you’re using your employee contribution either.
main question was is #2 and #3 considered different businesses even though I am a sole proprietor for both. Do they both feed into one 401k pot or are they considered “unrelated employers? My CPA tells me that she is not sure since in both income streams I am a sole proprietor/physician so I outright own both businesses so to speak.
In #3 I am a sole proprietor as a minority k1 partner and in #2 I am a sole proprietor 1099 contractor.
Any info or insight is appreciated.
Not sure what you mean by “I am a sole proprietor as as minority K1 partner.” If you’re a partner and you don’t own most of it, it should be a separate business from the other two and thus a whole other $66K limit. But if business # 2 owns # 3, then it would be the same business and have the same 401(k).
Thanks for the help.
I am just throwing out the labels that were discussed with my CPA and my search on this forum and around the internet. What I meant is that I am an unincorporated physician who operates as a sole proprietor. For the K1, I am a limited partner. For the 1099, I am a sole proprietor. The reason I brought this up is that CPA though that due to me being unincorporated, the 1099 and k1 feed into the same business which is my status as a sole proprietor. So I am just trying to clarify things in my mind to decide on how to proceed with my taxes.
And to answer a prior question, the employee contribution component is through the K1, part of how the K1 partnership set-up our benefits as I understand it.
Thanks!
If they feed into the same business then you certainly don’t get separate 401(k) limits for them. Your individual 401(k) and your partnership 401(k) share the same limit IMHO. So if you do what you’ve outlined, you’re overcontributing. Not sure anyone will notice though and you can certainly claim ignorance since few understand these rules.
Thanks for your help thinking this through, Jim. My CPA doesn’t seem to know much about it and despite trying to dig deeper, agrees with you that I can’t get more than 401k limit. So best to play it safe for now unless more info comes to light.
However, for 2023 one thing I am considering would be contributing as an employee 401k contribution to my hospital employee w2 position. So, that would look like this…
w2: $22,500 employee contribution plus whatever profit sharing is put in by employer
k1/1099: $66,000 employer contribution.
That would allow me to contribute an additional $22,500. Am I thinking about this correctly?
Yes.
Thanks for the site and answering my question in advance. I am under 50 in the following situation and wondering how much I can put away between my two 401ks.
in 2023:
I worked for an employee as a W-2 and maxed out my 401k for the year 22,500. There was 0 match/profit sharing etc. Technically, my prior employer could have given me up to 43,500 to meet the $66k cap. I’ve also left that job.
I also have an S corp business and a solo 401k with considerable income. These companies are unrelated. I pay myself a salary as an employee. I realize I can’t contribute anymore from the employee W-2 side since I’ve maxed out my elective deferral amount of 22,500 with my prior job.
However, on the EMPLOYER profit sharing/match side of things for my S corp, how much can I put into my solo 401k from the employer side? Is it $66,000 or $43,500 (66,000 – 22,500 from my employee contribution at my old job).
I get mixed messages on the net and my CPA was unsure even. I will meet all the income and percentage requirements to max 66,000 if need be (the 25% of income rule).
Thanks,
$66K but no more than 25% of the salary you’ve paid yourself.
Hey Jim and WCI community,
I am part of a private orthopedic group, and my income from the practice, as well as separate income from trauma call stipends, come through an S-corp. I will max out my $66k 401k contribution through the group’s profit sharing plan as well as my employee contribution in the group’s 401k. My wife is now an employee of my corporation. Am I able to create a solo 401k through my S-corp for my wife and have her contribute to that with her income from the S-Corp? The group 401k consultants were unsure if it would violate non-discrimination testing for profit-sharing in the group plan, but I am able to fund her salary entirely from my trauma call stipends, which is income entirely separate from the orthopedic group. Hope the question makes sense, I can’t seem to get a definitive answer from anyone. Thank you very much for your help.
Several observations. If your consultants (ideally, ERISA fiduciaries) are not able to help you with something like that, probably time to find new ones, as this is part of their job! They should reach out to their internal or external ERISA attorney for advice, at the very least.
There are affiliated service group concerns here. For one thing, you can not create a solo 401k for that S corp as it constitutes an affiliated service group with the other entities in your practice, and as such it would be part of the practice retirement plan. I would keep the S corp for the practice distinct and separate from your other income, and set up another entity just for the solo income, which can hire your spouse (and set up a solo 401k). Otherwise you won’t be able to hire your spouse without creating issues. This would be a good question for an ERISA attorney just to make sure you are doing everything correctly. I’m going by what’s presented here, and there may be other facts and circumstances that can impact this determination.
I agree with Kon’s advice. Don’t run the 1099 income through the S Corp.
Hi. My spouse and I have separate solo 401k plans (let’s call them Plan A and Plan B), which we opened a few years ago when we undertook self-employed activities. This year, we opened an LLC as QJV and are looking to consolidate those solo 401k plans into one (let’s call it Plan C).
Furthermore, after some research, it seems that in community property states, we’re considered a Controlled Group and can only have one solo 401k plan. However, we have two solo 401k plans and need to fix this as soon as possible.
We are trying to understand the best course of action.
Option #1:
1) Adopt a new solo 401k plan (Plan C)
2) Perform trustee-trustee transfers from Plan A and B to the new Plan C
3) Close the old solo 401k plans (Plans A and B)
Option #2:
1) Amend (restate) Plan A so it becomes Plan C
2) Perform a trustee-trustee transfer from Plan B to the new Plan C
3) Close solo 401k plan (Plan B)
Option #3:
Create a controlled group plan, which will list both Plan A and Plan B in the solo 401(k) plan documents (Plan C).
It seems like Option #1 is the simplest one, but I’m unsure if it’s ok to do it. Option #2 acts as a middle ground, but its benefits compared to Option #1 aren’t very clear to me. Option #3 appears to be the most complex.
Can we go with Option #1 in our case?
Technically, as long as these solo 401k plans are roughly the same (which they mostly are), you should be fine from compliance standpoint (and you don’t have any employees, which makes it fairly straightforward). Before you rush to do anything, starting in 2024 you will not be a controlled group any longer. Unfixing it will be more trouble than it is worth because once you have a single 401k for two unrelated entities, you are a Multiple Employer Plan, which requires its own complexities (and to fix that you need separate solo 401k plans!), so don’t do anything and you will be just fine starting in 2024. Aren’t retirement plans fun?
Thank you for your answer. So, if I understood you correctly, you’re saying that we should just keep Plans A and B because in 2024 the controlled group will not be an issue due to the SECURE 2.0 Act. It makes sense. At the same time, we want to open Plan C anyway because the current Plans A and B, opened through Fidelity, do not have Roth Solo 401k and alternative investment options. So, we wish to open Plan C for LLC anyway and it seems like in 2024 we can have the old Plans A and B as well as Plan C. Is that correct?
Also, by the way, do you know if the SECURE 2.0 Act removes the SEP IRA from the pro-rata rule?
I do not believe that it does. I saw nothing about that in Secure Act 2.0. The new Roth SEP IRA accounts yes, but not the regular old tax-deferred SEP money.
I’ve been talking with ERISA attorneys and there may be a way to create a ‘defective’ controlled group to still end up with a single plan, but you’ll need to find an ERISA attorney who can do it for you.
Otherwise, if you want to replace your two solo k plans, you would probably want to open two new ones and move the money from the old ones there.
Interesting. Another example where doing nothing might be the easiest and best option.
Doesn’t matter too much. Whether you have 1, 2, or 3 plans, you only get two $66K contributions, one for each of you.
So I’d try to keep it as simple as possible with one plan if I could pull it off. I think either option # 1 or option # 2 are allowed, but just talk to whoever is setting up the new plan and have them help. I’d just follow their advice.
Can I put the money for my multiple solo 401ks from my unrelated employers into the same Vanguard solo 401k account.
1. I have a govt TSP which I maxed out my 22500 limit for 2022. The govt matched 5%
2. I have a solo 401k vanguard account which I was able to max out at 43500 employer contribution for side doctor work with an upcoming 1099 of ~300k income
3. I was paid for research by a separate company at 10k on an upcoming 1099. Can I put the 20% / 2k into the same vanguard account for #2 or do I need to open up an entirely different account for this 2k.
Thank you!
You can’t use a solo 401(k) if you’re an employee. But if you’re self-employed and you have two clients, you would only get one solo 401(k) because there is only one business there, your business.
Your businesses 2 and 3 are the same business in the eyes of the IRS as far as retirement plans go. So one 415(c) $66K limit and you would just use the same solo 401(k). Try to use the same EIN for both of those clients (the doctor work client and the research client).
I apologize for potentially asking the question unclear. Are businesses 2 and 3 considered separate unrelated employers to the IRS for which I would have two $66,000 limits? if so, can I put the money in the same Vanguard solo 401(k) account? Business 2 is physician work with a 1099 that is separate from business 3 which is research work from an entirely different company with its own 1099.
They’re not employers at all. You are the employer. They’re clients. Businesses pay other businesses, not employees, on a 1099. I understand they’re different companies but since you own both of them they’re consider one by the IRS for retirement plan purposes. I’m sorry. This isn’t controversial, it’s just the way it is.
My current employer’s 401k plan has high fees. Is it possible for my current employer to also sponsor an “Individual 401(k) Plan” (through Schwab that has low fees) specifically for me, and essentially let me contribute to 2 different 401k plans, given the $19,500 limit isn’t exceeded in aggregate?
Maybe. Not all record-keepers allow in-plan self-directed brokerage accounts. It doesn’t hurt to ask about SDBAs, your current record-keeper has to be integrated with Schwab PCRA in order for your plan to be able to offer this to plan participants. They will most likely refuse to handle outside SDBAs just for you. If your plan allows SDBAs, this should be set up by the plan sponsor for the use by plan participants. Depending on the size of your plan, negotiating lower fees is always an option provided you can convince the key decision-makers that this is in their best interest to do so. It is relatively easy to convince doctors/partners that paying high fees on their personal investments is not something that is good for them over the long term:
https://www.whitecoatinvestor.com/evaluating-aum-fees-small-practices/
Kon-
I don’t think he’s just asking about an SDBA, but a totally separate plan.
Looks like OP is thinking about a Schwab SDBA as a way to escape his current fees in the plan. So OP is aware that it is basically an extension of the current account. In effect, having an in-plan or outside SDBA is exactly like having another 401k account. Setting up an outside SDBA is never happening, that’s for sure. However plan level SDBA may still be possible. Some plan sponsors are totally oblivious about this, even some on Vanguard platform which has an easy access to Schwab PCRA. Others decided not to include it for various reasons, compliance being one of them. Still others never had anyone request it, so they never set it up.
Correct, I am not asking about a SDBA, but an “Individual 401(k) Account” also referred to as a “Solo 401(k)”: More details below:
https://www.schwab.com/small-business-retirement-plans/individual-401k-plans
That being said, still very glad to hear the comments about the SDBA.
This is never an option. The only plan is the practice plans. You can only have an SDBA, never a solo 401k. Not unless you have any side 1099 income that’s eligible for a solo 401k.
Possible? Not if there are other employees.
Likely. No way is anyone ever going to do this.
Allow me to ask another question open to everyone’s/anyone’s opinion – Recently my company held a 401(k) meeting with the entire company and the different on-staff financial advisors present.
After the meeting, an employee sent out a company wide email that had some good information comparing the investment options, told us her favorite option, and recommended a relevant book that she had read on 401(k) investing.
This employee was immediately reprimanded for sending “financial advice” to the entire company and in addition to being “inappropriate”, was opening herself up to personal legal ramifications.
1. Do you agree or disagree that it’s inappropriate or beneficial to send financial tips to your coworkers? Is talking about finances taboo?
2. Maybe she should have not sent a company wide email, but how is illegal to make a stock suggestion. Don’t people do that all the time?
If this can be considered as an official company email or an email coming from someone who has the ability to send a company-wide email, this is indeed inappropriate. Companies should leave this type of emails/advice to the companies serving them. While you can give financial tips to coworkers directly, doing so for the whole company using official email is not the right way to do it. This has nothing to do with not talking about finances but everything to do with ERISA and what company role is under ERISA. While a company can institute a financial education program, company itself should not be providing financial education to participants to avoid liability. This information should come from appropriately selected entities that specialize in this type of education, and that have fiduciary status under ERISA. This type of fiduciary would ideally shield the company from any liability related to providing certain type of advice and information. Companies have certain obligations under ERISA, and they often outsource some of these obligations to limit their fiduciary liability. This is one such example. If someone follows this advice, invests money, ends up losing money and then sues the company, the company can potentially be liable. This doesn’t mean they are wrong or will necessarily lose. But even the exposure to such a liability is enough to make most companies want to distance themselves from providing investment advice or what can be considered investment advice.
1. Depends on the format. A company wide email? Probably a bad format. Putting it on your own personal blog and noting that it is your own opinion? That’s probably fine.
2. It’s not illegal. But as Kon noted, it puts the company at risk due to its fiduciary duty to the employees.
It is crazy how convoluted these details can become. I started the year as a W2 employee but transitioned to full time 1099 at the start of February. I had contributed ~$3500 via elective deferrals to my 403b & received ~$1500 employer match/employer non-elective contributions prior to leaving.
I understand my employee contribution to my solo 401k now can only be $19k ($23k-$3.5k) but do I also have to subtract out the 403b employer contribution from the overall $69k max limit for 2024? I guess what I am asking is if I need to subtract out all money contributed (employee + employer) to my 403b from the $69k max amount allowed in my 401k or if it is just the employee contribution I have to subtract out? Thanks!
Yes, but only because it’s a 403b.
Hi, thank you so much for this article! Though I definitely now have more questions than before I read it! I own a dental specialty practice. We currently do an IRA for myself and my employees. We are trying to figure out if it makes sense to switch to a 401k. I employ each of my children as W2 employees (small amount each, 3,500, as the are young). My husband is an engineer and has a 401k through his employer who gives 4% plus 3% match for a total of 7%. How would we go about determining if it makes sense to switch to a 401k for my practice, and if we do, how to structure it, taking into consideration all of the above points, and if we do, whether or not it makes sense to put my husband on payroll?
Here’s a reference link:
https://www.whitecoatinvestor.com/the-ideal-retirement-plan-for-your-practice
In short, here are major considerations:
1) Your net income has to be at least $400k-$450k. A 401k plan makes more sense when you want to maximize profit sharing.
2) You have 5 or fewer staff, and they are mostly younger than you. If your have 10+ staff and many are older than you, this could be an issue as far as maximizing PS.
3) It does not make sense to add your husband to the payroll as he’s already maximizing his employee contribution. This is only in play if you have a Cash Balance plan and a 401k plan, but this would require a net income of at least $800k-$1M, and setting his W2 to at least $100k-$200k.
Without doing an illustration it is impossible to tell whether a 401k would be better, but in general, if you have fewer than 5 staff, and they are all younger, and you make above $450k, a 401k plan would be good (even better if your joint income is in the 35% marginal bracket or higher).
If your practice income is at least $600k, you are probably in a position to consider a Cash Balance plan in addition to a 401k plan.
Thank you for your response! A couple points of clarification – my kids are not my only employees, I just mentioned them as that could matter in the decision making process. I have 10 actual employees (in addition to my kids), half of them being about my age or older (40), and half being about 10-15 years younger. Practice income about 650k, hoping for more in the next few years due to continued growth.
Kids are not going to be part of any 401k plan. With 10 employees, profit sharing is going to be very challenging. Typically when this is the case, and the income is much higher than $450k, we move on to the Cash Balance plan option:
https://www.whitecoatinvestor.com/cash-balance-plans-for-solo-and-group-practices/
This is because the cost of PS is very high with 10 employees. Though ideally practice owner’s age has to be at least 40 (or close enough), so that Cash Balance plan contribution is at least $120k. A $650k net profit is not enough to employ the spouse, as your own W2 would probably have to be $345k for optimal results.
Not a DIY project with your employees. Hire someone on our list (like Konstantin) to help once you have non family employees:
https://www.whitecoatinvestor.com/retirementaccounts/
Also read this: https://www.whitecoatinvestor.com/why-i-gave-my-business-away/
As far as hiring a spouse, you’re usually better off hiring your kids than your spouse as an employee. People think there’s a big tax break there for another 401k, but it costs so much in payroll taxes I suspect it isn’t worth it most of the time.
Thanks for all that you do. Here is my situation:
1. W-2 employee where I max out my employee 401k contribution annually (23k in 2024). There is about 10k match.
2. Self-employed 1099 income of ~400k as sole proprietor.
Can I contribute 69k into my solo 401k as 100% employer contribution in 2024? Or am I capped at 46k (69k – 23k employee contribution through my W-2 job)?
Yes. No.
Question regarding full time employment as well as owning a single employee LLC. Both have 401k. Regarding Employer contributions. Is the employee limit based on combined income, or is per employee? Trying to maximize employee contributions. Currently make substantially more from full time and trying to maximize the LLC employee contribution.
You get one employee contribution across all 401(k) accounts, although after-tax employee contributions aren’t so limited. I need more specifics to help you.
It would help to know if the LLC is a sole prop or an S corp too.
I recently exited Vanguard solo 401(k) (after vanguard decided to sell this business to
Ascensus) to roll entirely into my Solo 401(k) with Schwab. This triggered a reminding email from Vanguard that I need to file an IRS form 5500-EZ, which after digging into it I then realized I have never filed such a form and my accountant never reminded me to do so! One needs to file 5500-EZ for informational filing to the IRS whenever the combined total balance of all the solo 401(k)’s is more than 250,000, or when one is terminated or distributed etc..
So I am facing a hefty penalty for non-filing (500/day or 150,000/year in delay)! And I am late for at least five years!! I have to look for a new accountant and is there any way to appeal or reduce this penalty? This will essentially wipe out the entire account balance!
Man I’m sorry to hear that. We’ve been warning about this for years but I know it’s hard to read everything we put out. My recollection is Vanguard usually sent out a form reminding you to do it too, but it’s been a while since I had a Vanguard Solo 401(k) so maybe that isn’t true. Read these now along with the comments on them:
https://www.whitecoatinvestor.com/irs-form-5500-ez/
https://www.whitecoatinvestor.com/late-5500-ez-form/
https://www.whitecoatinvestor.com/five-worst-tax-penalties/
Hopefully you can still get away with a minimal or even no penalty at all.
Make use of the penalty relief program for Form 5500-EZ late filers. The fee is $500 per delinquent return.
https://www.irs.gov/retirement-plans/penalty-relief-program-for-form-5500-ez-late-filers
I work part time W-2 for the VA and am eligible for the catch up contributions. I max out my TSP including the catch up dollars. I also work full time W-2 for a critical access hospital that has a 403b. Because these are unrelated employers, can I maximize my 403b contributions in the same year, including the catch up dollars in the 403b?
You get one employee contribution no matter how many 403bs/401ks/TSPs you’re eligible for. If maxing out the employee contribution in one plan, you can’t then make it in another plan. At least you can’t deduct it beyond the limit. The money that goes in a second plan generally needs to be employer contributions.
Of course, I don’t get the sense this is audited very frequently though if you wanted to risk it. But that’s the rule.
I have a specific question that I’m hoping you might be able to help with…
In 2023, I had W2 and 1099 income with contributions as follows:
– I contributed $22,500 to 403b plan through W2 job
– W2 employer contributed $6,389 to same 403b plan above
– (also $6,500 via Backdoor Roth)
Since the 2023 contribution limit is $66k, am I correct that my MAX Solo 401k contribution from my 1099 income would be $37,111 ($66,000 – $22,500 – $6,389) made as an employER contribution? Or, do I exclude my W2 employer contribution ($6,389) for a MAX of $43,500?
Thanks so much!
Yes. you can put in a maximum of $37,111 into that solo 401k either as an employer contribution OR an after-tax employee (MBDR) contribution. The second requires you to earn less. The 415(c) $66K ($69K this year) limits are combined for a 403b/solo 401k, unlike a 401k/solo 401k.
I’m feeling stupid.
I do locums on W2 for three unrelated medical services/hospitals. Each offers a 401K. I have already contributed $30k to the 401K for employer A. That means I cannot contribute anything to the other two, correct? Employer A can add another $43, 500, and employers B and C each put in $73,500, but I am not allowed to add anything to those accounts.
As a W2 employee, I believe I cannot start a solo 401K or contribute to a SEP-IRA unless I incorporate and go to 1099 payments
B and C offer matching contributions, while A is changing to a “nonelective safe harbor” so I should split up my contributions for 2025 between B and C, and put in nothing into the 401k for A. Previous years they had a “basic safe harbor”, which the fund manager just told me is based on the compensation during the months that I funded the plan. So since I had funded the plan over the first six pay periods plus three pay periods in Sept/Oct for the catch up contributions, he told me the “total compensation” used to calculate the 100% match of my contributions up to 3% total compensation , plus 50% match up to 5% total compensation was the total for only those 9 pay periods, not the “wages” that appeared on my year end W2 which is what I considered “total compensation”. Live and learn.
Not as an employee contribution.
I’m also not 100% sure on whether the catch-up gets added to the $69K limit in ALL of the other plans. That might not be the case. The answer might be somewhere else on this page though, there are >1300 comments made over many years.
No, you can’t start a solo 401k without self employment income. And you don’t want a SEP IRA anyway, but same rules.
Yes, you can probably get more matching dollars by splitting up your contributions between plans.
What is the limit for AFTER-TAX employee contributions across two different unrelated jobs/employers?
• Elective deferrals are limited to $23,500 in 2025 (add’l $7500 if age 50+) combined for BOTH jobs/employers.
• Total maximum contributions (elective + employer + after-tax) are limited to $70,000 in 2025 (add’l $7500 if age 50+) for EACH employer.
But if someone contributes the $23,500 elective deferral into the first employer’s 401k (a W-2 job, and it goes all to the Roth bucket of the 401k), earns $400,000 as a sole proprietor, and sets up a solo 401k that allows for after-tax contributions and in-plan conversions, can they hypothetically contribute up to the $70,000 limit to this solo 401k entirely as employee after-tax contributions (with no employer contributions) therefore allowing for a total of $93,500 to be contributed to Roth 401k accounts ($23,500 with the W-2 employer and another $70,000 using the so-called “mega back-door” method)?
I’m not sure if you add $7,500 for EACH employer or not. I need to figure it out though because I turn 50 next year.
But yes, you can put your entire $70K (2025) limit in as an after-tax contribution if the plan allows it. That’s what I do with the WCI 401(k) every year.
Theoretically, if your employer plan allowed it, you could do this in both 401(k)s and put in $140K into Roth.
Thanks for the response.
As for the age 50+ additional $7500, this amount is aggregated across multiple accounts and cannot be used multiple times for each employer (according to Mark Nolan, Founder and COO of My Solo 401k Financial who stated this in a live webinar).
So, using that theoretical scenario, for age 50+ in 2025, as long as the net self employed income was high enough, one could contribute $77.5 to the 401k with the W-2 job, plus $70k to the 1099 gig, totaling $147.5k into Roth. One would obviously only consider this if there was no employer match or contribution at the W-2 job.
Mark would know. Thanks for sharing.