One Box on Your W-2 Decides Everything

Two people. Both 62. Both pulled in $300,000 last year. On January 1, 2026, one of them loses the right to make pre-tax catch-up contributions to a 401(k). The other keeps it.

The difference is one box on one form.

The Rule

Congress needed cash. Not future cash. Cash now. So buried inside SECURE 2.0, they wrote a rule: if you're 50 or older and earned more than $150,000 in FICA wages from your employer last year, your catch-up contributions must be Roth starting January 1, 2026.

Catch-up contributions are extra money you can stuff into a 401(k) once you hit 50. For 2026, the regular catch-up limit is $8,000. If you're between 60 and 63, it jumps to $11,250.

Pre-tax means you pay the IRS later. Roth means you pay the IRS now. Congress pulled future tax dollars into the present budget window. Same tax dollars. Different decade. Neat trick.

The Trigger Nobody Reads

Here's the part that matters. The $150,000 test doesn't use your total income. It doesn't use your gross pay. It doesn't use your adjusted gross income.

It uses Box 3 of your W-2.

Box 3 is your Social Security wages under IRC §3121(a). That's a specific number. And things sneak into it that you don't expect.

Your salary counts. Your bonus counts. Your 401(k) deferrals count. They reduce your income tax, but FICA doesn't care. They stay in Box 3.

And if your company pays you in restricted stock units, the value at vesting counts too. So you earn $140,000 in salary. Your RSUs vest and add $50,000. Your Box 3 reads $190,000. You're over the line. Your "salary" is below the threshold. Your Box 3 is not.

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The Ceiling That Makes It Dumb

Look. Box 3 has a cap. For the W-2 from last year (2025), Social Security wages maxed out at $176,100. Earn $180,000 and your Box 3 reads $176,100. Earn $500,000 and your Box 3 still reads $176,100.

A senior VP making half a million and a project manager making $180,000 have the same Box 3.

The Escape

Now the fun part.

An individual who did not have any FICA wages from the employer sponsoring the plan for the preceding calendar year (for example, a partner who had only self-employment income) would not be subject to the Roth catch-up requirement under the plan in the current year.

I mean. Read that again.

A partner at a law firm pulls $400,000 on a K-1. Schedule SE. No W-2. No FICA wages. Box 3 doesn't exist. The rule never fires. They keep pre-tax catch-ups. Their AGI stays lower. Their Medicare premiums stay lower two years from now.

Meanwhile, a W-2 employee earning $150,000 loses pre-tax catch-ups because their Box 3 cleared the threshold by a few hundred bucks.

Same country. Same tax code. Different form.

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The Lockout

This is the worst part. And it's quiet.

If your employer's 401(k) plan doesn't offer a Roth option, you can't make Roth catch-up contributions. And if you're over the $150,000 FICA wage line, you can't make pre-tax catch-ups either.

Your catch-up limit drops to zero. Not reduced. Zeroed.

Not because you did something wrong. Because HR didn't update a plan document. Employers have until December 31, 2026, to amend the plan. Some will. Some won't notice until February.

The Box

Two people. Same age. Same income. One files a W-2. One files a K-1. The rule sorts them into different worlds.

It doesn't sort by wealth. It sorts by one box on one form.

Pull your W-2. Find Box 3. That's the number that matters now.

Right?

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