This bill amends the Internal Revenue Code to limit retirement account contributions and mandate increased minimum distributions for high-income taxpayers with aggregate retirement balances exceeding $10 million.
Richard Neal
Representative
MA-1
This bill amends the Internal Revenue Code to impose stricter contribution limits and increased distribution requirements on high-income taxpayers with aggregate retirement account balances exceeding $10 million. Starting in 2027, it restricts new contributions for these taxpayers, and beginning in 2034, it mandates higher annual distributions from their retirement plans. These measures aim to limit the accumulation of tax-advantaged wealth in large retirement accounts for high-earners.
The government is looking to put a ceiling on the 'mega-IRA.' This bill targets high-income taxpayers who have managed to grow their retirement nests to over $10 million. If you fall into this bracket—earning over $400,000 as an individual or $450,000 as a married couple—the bill effectively locks the door on new contributions once your total vested balance across 401(k)s, IRAs, and other plans hits that $10 million mark. Starting in 2027, if your balance is, say, $9.8 million, you can only contribute up to the $200,000 remaining gap. If you’re already at $10.5 million, you’re done contributing for the year. This isn't just a suggestion; Section 1 backs this up with a 6% excise tax on any excess contributions you try to sneak in.
It’s not just about what you put in; it’s about what you’re forced to take out. Under Section 2, the bill introduces a 'super-sized' version of Required Minimum Distributions (RMDs) that kicks in after 2033. If you’re an 'applicable taxpayer' with more than $10 million in the bank, you’ll have to withdraw 50% of whatever amount sits above that threshold. If your accounts are truly massive—double the threshold—the rules get even more aggressive, forcing you to empty out Roth accounts first to satisfy the requirement. Think of it like a pressure valve for wealth: once the tank gets too full, the law forces a release, moving that money out of tax-advantaged shelters and into the broader economy (where it can be taxed).
Imagine a tech executive or a successful small business owner who has spent thirty years Maxing out their 401(k) and making savvy investments. If they wake up in 2034 with $12 million in their accounts, this bill treats all those accounts as one giant bucket. They would be required to pull out $1 million (50% of the $2 million excess) in a single year. While the bill generously waives the 10% early withdrawal penalty for these forced distributions, it mandates a 37% federal tax withholding on the spot. You can’t opt out of that withholding unless the money is coming from a Roth account that’s already met its holding period requirements. It’s a significant liquidity event that could drastically change a family's long-term estate planning.
To make sure these numbers don't get stuck in the past, the $10 million cap and the income thresholds will start adjusting for inflation annually beginning in 2028. The bill also forces retirement plan providers—the folks managing your 401(k) or 403(b)—to change their internal rules to allow these 'excess' distributions, even if the plan normally has strict lock-up periods. While this mostly affects the top 1% of savers, it represents a fundamental shift in how the tax code treats long-term wealth accumulation. The goal is clearly to stop retirement accounts from becoming permanent, tax-free dynastic wealth funds, ensuring they are used for their original purpose: funding an actual retirement.