Self-Employed Retirement

You can shelter far more than any W-2 employee. Here is how.

A W-2 employee maxing out a company 401k defers taxes on $24,500 a year. A self-employed professional with the same income can defer three times that amount, and a high-earning business owner over fifty can shelter north of $300,000 annually using the right combination of plans. The difference comes down to one fact: when you are self-employed, you make both the employee and the employer contribution yourself. Most solo owners stop at a SEP IRA because it is easy to open, then leave tens of thousands of dollars of deductions on the table every year.

This guide covers the full toolkit: SEP IRA, SIMPLE IRA, Solo 401k, Safe Harbor 401k, profit sharing, Cash Balance plans, and Defined Benefit plans. We organize them by income level, employee count, and sheltering goal so you can identify the right vehicle for your situation.

This guide provides general information rather than personalized investment, tax, or legal advice. The numbers and frameworks describe how the relevant strategies typically work for the broad population of tech employees with concentrated equity, but they cannot account for your specific cost basis, vesting schedule, state of residence, marriage status, charitable intent, estate plan, AMT carryforwards, or holding-period clocks, all of which materially change the answer in any individual case. To run the numbers on your actual situation, talk to an advisor.

Part one.
The decision framework

What is the best retirement plan for self-employed and small-business owners

The best retirement plan for a self-employed person depends on three variables: annual income, whether you have employees, and how much you want to shelter each year. Solo owners earning under $150,000 with no employees often start with a SEP IRA for its simplicity. Solo owners earning more, or those who want Roth and loan features, usually benefit from a Solo 401k. Business owners with employees who want to avoid discrimination testing turn to Safe Harbor 401k plans. And high earners over fifty who want to shelter $200,000 or more per year layer a Cash Balance or Defined Benefit plan on top of a 401k.

The contribution ceilings differ dramatically across vehicles. A SEP IRA and a Solo 401k both max out at $72,000 in 2026; the Solo 401k adds an $8,000 catch-up for owners 50 or older, reaching $80,000, while a SEP IRA has no catch-up. A Cash Balance plan layered on top of a 401k can push the total above $300,000 for owners in their mid-fifties and beyond. A self-employed owner can shelter far more than a W-2 employee for a structural reason: you fund both the employee and the employer side of the contribution yourself.

Choosing the wrong plan is expensive. A solo owner earning $250,000 who sticks with a SEP IRA when a Solo 401k would let them contribute more leaves money on the table every year. A business owner with employees who ignores Safe Harbor design spends time and fees on annual discrimination testing. A high earner who never layers a Cash Balance plan misses the largest deduction vehicle available. The rest of this guide walks through each vehicle so you can match your situation to the right structure.

Why the self-employed can shelter more than W-2 employees

A W-2 employee contributes to a 401k through payroll deductions. The employer may add a match, but the employee has no control over the match formula or whether the plan exists at all. The combined contribution limit under Section 415(c) is $72,000 in 2026, but most employees never get close because employer contributions are discretionary and capped by plan design.

A self-employed owner wears both hats. You are the employee who can make elective deferrals up to $24,500 in 2026, and you are the employer who can make profit-sharing contributions up to 25 percent of net self-employment income. You control both levers. If your income is high enough, you can hit the $72,000 ceiling entirely with your own dollars. No one else needs to contribute on your behalf.

The defined-benefit side of the tax code opens an even larger door. A Cash Balance or traditional Defined Benefit plan calculates contributions based on your age, target retirement benefit, and assumed investment returns. Because older owners have fewer years to fund the benefit, the annual contribution limit rises with age. A 55-year-old can often contribute $200,000 or more per year, and a 60-year-old can exceed $250,000. Layering a defined-benefit plan on top of a Solo 401k is how high-income self-employed professionals shelter $300,000 or more annually.

Three tiers of complexity and contribution capacity

Self-employed retirement plans fall into three tiers based on how much you can shelter and how much administration they require. Understanding the tiers helps you pick the right starting point and know when to upgrade.

Tier one: IRA-based plans. SEP IRA and SIMPLE IRA are the simplest to open and maintain. Setup is a single IRS form, and there is no annual filing until assets exceed $250,000. The tradeoff is lower contribution capacity and fewer features. A SEP IRA accepts only employer contributions, so if your income is modest, you may not be able to contribute as much as you could with a Solo 401k. A SIMPLE IRA has an even lower ceiling but permits employee contributions and is designed for businesses with a small staff.

Tier two: Solo 401k and Safe Harbor 401k. These plans accept both employee deferrals and employer profit-sharing contributions, unlocking the full $72,000 ceiling. A Solo 401k requires no annual filing unless assets exceed $250,000, at which point you file Form 5500-EZ. A Safe Harbor 401k triggers when you add employees and need to avoid discrimination testing. Administration increases, but so does contribution flexibility.

Tier three: Cash Balance and Defined Benefit plans. These are actuarially designed, require annual compliance, and cost more to administer. The payoff is the ability to shelter $100,000 to $300,000 or more per year. If you are over 45, earn $300,000 or more, and expect consistent high income for at least five to ten years, the administrative cost is a rounding error compared to the tax savings.

Part two.
The IRA-based and 401k-based vehicles

SEP IRA and SIMPLE IRA: the IRA-based starters

A SEP IRA allows you to contribute up to 25 percent of net self-employment income, to a maximum of $72,000 in 2026. Setup is a single IRS form, and the plan can be established as late as your tax-filing deadline including extensions. The SIMPLE IRA has a lower ceiling of $17,000 in employee deferrals plus a 2 or 3 percent employer match, but it permits employee contributions, making it useful for businesses with a small staff. Neither plan offers Roth contributions or participant loans, and the SEP requires equal percentage contributions for any eligible employees.

SEP IRA contribution math. Your maximum contribution is calculated on net self-employment income after deducting half of self-employment tax and the contribution itself. The circular calculation results in an effective rate of about 20 percent of gross Schedule C income for sole proprietors. For S-corp owners, the contribution is based on W-2 salary, and the 25 percent limit applies directly.

SIMPLE IRA fit. The SIMPLE IRA makes sense when you have a handful of employees and want to keep administration light. Employees can defer up to $17,000 in 2026, and you as the employer must either match up to 3 percent of compensation or make a 2 percent nonelective contribution for all eligible employees. The lower ceiling means solo owners with no employees are almost always better served by a SEP or Solo 401k.

When to graduate from a SEP. If your income is below roughly $150,000 and you have no employees, a SEP IRA is often enough. Once your income rises or you want Roth elective deferrals, participant loans, or the ability to contribute more at lower income levels, the Solo 401k becomes the better tool. The SEP is easy to open, but it is not always the plan that maximizes your deduction.

Solo 401k: deferrals, profit sharing, and Roth options

A Solo 401k lets you contribute as both employee and employer. As an employee you can defer up to $24,500 in 2026, or $32,500 if you are 50 or older and eligible for the standard catch-up. The new SECURE 2.0 super catch-up raises that to $35,750 for participants aged 60 to 63. As an employer you can add a profit-sharing contribution of up to 25 percent of net self-employment income. Total contributions can reach $72,000, or $80,000 with the standard catch-up, and even higher with the super catch-up. Unlike a SEP, the Solo 401k supports Roth elective deferrals and, if the plan document allows, after-tax contributions that can be converted to Roth via a mega-backdoor strategy. Participant loans up to 50 percent of the vested balance are also available.

Why the Solo 401k beats a SEP at lower income levels. Suppose you earn $100,000 in net self-employment income. A SEP IRA allows an employer contribution of about $18,587 after the circular deduction. A Solo 401k allows a $24,500 employee deferral plus the same $18,587 employer contribution, totaling $43,087. The difference is $24,500 of additional tax-deferred savings, which at a 35 percent marginal rate saves you $8,575 in federal tax alone.

Roth elective deferrals. The Solo 401k allows you to designate your $24,500 employee deferral as Roth, meaning you pay tax now but never pay tax on qualified withdrawals. If you expect your tax rate to rise or you want tax diversification in retirement, Roth deferrals are valuable. SEP IRAs now technically permit Roth contributions under SECURE 2.0, but few custodians support them yet.

Mega-backdoor Roth conversions. If your plan document allows after-tax contributions beyond the $24,500 deferral limit, you can contribute up to the $72,000 total limit as after-tax dollars and immediately convert them to Roth. This is the mega-backdoor Roth strategy. It requires a plan document that explicitly permits after-tax contributions and in-plan Roth conversions. Not all custodians offer this feature, so confirm before opening the account.

Form 5500-EZ filing. Once plan assets exceed $250,000 at year-end, you must file Form 5500-EZ annually. The form is straightforward, but missing the deadline triggers penalties. Set a calendar reminder for July 31 each year, or the extended deadline of October 15 if you file an extension.

Safe Harbor 401k and profit sharing when you have employees

Once you hire employees who meet eligibility rules, a Solo 401k becomes a standard 401k subject to nondiscrimination testing. Safe Harbor 401k plans sidestep those tests by requiring the employer to contribute either a 3 percent nonelective contribution to all eligible employees or a 4 percent matching contribution. The Safe Harbor contribution is immediately vested and deductible, and it allows owners to maximize their own deferrals without worrying about top-heavy rules. For many small businesses, the cost of the Safe Harbor contribution is lower than the administrative burden of annual testing.

Why testing matters for owners. Nondiscrimination testing compares the contribution rates of highly compensated employees to everyone else. If highly compensated employees contribute at much higher rates, the plan fails and contributions must be returned or adjusted. Safe Harbor design removes this risk by ensuring rank-and-file employees receive a meaningful employer contribution regardless of whether they defer.

Profit sharing on top of Safe Harbor. A Safe Harbor 401k can include a discretionary profit-sharing component. This lets you contribute more when business income is strong and scale back in lean years. Profit-sharing contributions are not required every year, giving you flexibility while still avoiding nondiscrimination testing on the elective deferral side.

Cost-benefit analysis. If you have five employees earning an average of $60,000, the Safe Harbor 3 percent nonelective contribution costs $9,000 per year. In exchange, you can maximize your own $24,500 deferral plus profit sharing without worrying about testing failures. If the alternative is failed testing that forces you to return $10,000 of your own deferrals, the Safe Harbor cost is clearly worth it.

Part three.
The high-income plays

Cash Balance and Defined Benefit plans for $100K+ sheltering

A Cash Balance plan is a type of defined benefit plan that expresses benefits as a hypothetical account balance rather than a monthly pension. Contributions are calculated by an actuary based on your age, target benefit, and expected investment returns. A 55-year-old owner can often contribute $200,000 or more per year, and the maximum annual benefit at retirement can reach $290,000 in 2026. Layering a Cash Balance plan on top of a 401k profit-sharing plan lets high earners shelter $300,000 or more while splitting the deduction across plan types.

How actuarial math works in your favor. The IRS limits the annual benefit a defined benefit plan can pay at retirement, not the annual contribution. Because older owners have fewer years to fund the benefit, the required contribution rises with age. A 45-year-old might be limited to $100,000 per year, while a 60-year-old could contribute $250,000. The closer you are to retirement, the more the tax code lets you shelter.

Cash Balance versus traditional Defined Benefit. Both are defined benefit plans under the same IRS rules. The difference is presentation. A Cash Balance plan shows participants a hypothetical account balance that grows with pay credits and interest credits. A traditional Defined Benefit plan describes the benefit as a monthly pension at retirement. For solo owners, the choice is largely administrative. Cash Balance plans have become more common because the account-balance format is easier to communicate.

Layering strategy. You do not have to choose between a 401k and a Cash Balance plan. You can contribute to both. A typical structure for a 52-year-old earning $400,000 might look like $32,500 in elective deferrals, $30,000 in profit sharing, and $120,000 in Cash Balance contributions, totaling $182,500. The deduction reduces federal and state taxable income by the same amount, often saving $60,000 or more in a single year.

Commitment and consistency. A Cash Balance plan requires consistent funding for at least five to seven years. If your income fluctuates wildly, you could face required contributions in a year when cash flow is tight. Work with an actuary to model conservative assumptions. The plan should match your income stability, not just your income level.

How Derek, a 52-year-old S-corp consultant, shelters $180,000 a year

Derek's situation illustrates why high-income S-corp owners benefit from layering plans. The S-corp structure lets him split income between salary and distributions. The salary funds his 401k contributions, while the distributions remain free of self-employment tax. The Cash Balance plan adds a second deduction layer that a Solo 401k alone cannot reach.

The numbers only work because Derek's income is stable. If his revenue dropped to $150,000 in a future year, the Cash Balance plan would still require its minimum contribution, which could strain cash flow. Before adopting this strategy, model a downside scenario with your actuary. The plan should survive a bad year without forcing you to take on debt to fund it.

The other requirement is that Derek has no employees other than himself. If he hired staff, the Cash Balance plan would need to cover them with comparable benefits, which could make the strategy uneconomical. Solo owners and spousal businesses are the ideal candidates for this approach.

Case Study
Derek · Self-employed S-corp · Marketing Consultant · $350K revenue · 52 years old

Derek runs a solo marketing consultancy as an S-corp and earns roughly $350,000 in annual revenue. He pays himself a reasonable salary of $120,000 and takes the rest as distributions. His Solo 401k allows a $32,500 employee deferral because he is over 50, plus a $30,000 employer profit-sharing contribution based on his W-2 salary, totaling $62,500 through the 401k alone.

Derek layers a Cash Balance plan on top. His actuary calculates that at age 52, with a target retirement benefit of $290,000 annually starting at 65, the Cash Balance plan can accept an additional $118,000 contribution. Combined with the Solo 401k, Derek shelters $180,500 in a single year.

At a combined federal and California state marginal rate of roughly 47 percent, this $180,500 deduction saves Derek approximately $85,000 in taxes. The Cash Balance plan costs about $2,500 annually to administer. The net tax savings after administration costs exceeds $82,000.

Derek plans to fund the Cash Balance plan for thirteen years until retirement. Even if he sells the consultancy and closes the plan early, the accumulated balance can be rolled to an IRA. The strategy works because his income is predictable and he has no employees who would need to be covered under the Cash Balance plan.

When the Cash Balance strategy does not fit

A Cash Balance plan is not for everyone. The strategy requires high and stable income, a commitment to funding for at least five years, and a willingness to pay actuarial and administrative fees. If any of these conditions is missing, a Solo 401k or SEP IRA is the better choice.

Income volatility. If your revenue swings from $400,000 one year to $150,000 the next, a Cash Balance plan can create problems. The minimum contribution is set by actuarial calculation, not by your cash flow. You could owe $120,000 to the plan in a year when you can only afford $50,000. Design the plan with conservative assumptions, or wait until your income stabilizes before adopting it.

Short time horizon. The tax benefit of a Cash Balance plan compounds over time. If you plan to retire in three years, the administrative cost may not be worth the marginal deduction increase over a Solo 401k alone. The strategy shines when you have ten or more years of contributions ahead.

Employee coverage requirements. If you have employees, a Cash Balance plan must cover them with comparable benefits. The cost of funding employee benefits can erase the tax savings from your own contributions. The strategy is most cost-effective for true solo practices or spousal businesses where no other employees exist.

Liquidity needs. Contributions to a Cash Balance plan are locked until retirement or separation from service. If you might need to pull capital from the business for other purposes, tying up $120,000 per year in a retirement plan may not be wise. Balance retirement sheltering against near-term flexibility.

Earning $250,000 or more and wondering whether a Cash Balance plan fits your situation?Talk to an advisor
Part four.
Putting it together

The decision framework: three questions that point to the right plan

Start with three questions. First, do you have employees other than a spouse? If yes, you need a plan that passes or avoids discrimination testing. Second, how much do you want to shelter each year? If the answer is under $72,000, a Solo 401k or SEP IRA likely suffices. If the answer is $100,000 or more, you need a Cash Balance or Defined Benefit plan. Third, do you want Roth contributions or loan access? If yes, a Solo 401k beats a SEP. A fee-only fiduciary can model each scenario against your actual income and design the combination that maximizes your deduction.

No employees, under $150,000 income. A SEP IRA is the simplest path. You can open one at any major custodian, contribute by your tax-filing deadline, and deduct up to 25 percent of net self-employment income. If you want Roth deferrals or loan access, switch to a Solo 401k.

No employees, $150,000 to $300,000 income. A Solo 401k becomes the better tool because the employee deferral lets you shelter more at lower income levels and the Roth and loan features add flexibility. At this income range you can often hit the $72,000 ceiling, after which a Solo 401k and SEP IRA provide similar contribution capacity. The Solo 401k still wins on features.

No employees, over $300,000 income. Layer a Cash Balance plan on top of your Solo 401k. At this income level, you are likely hitting the $72,000 ceiling already. The Cash Balance plan adds $100,000 to $200,000 or more of additional deduction capacity depending on your age. The administrative cost is trivial compared to the tax savings.

Employees present. Move to a Safe Harbor 401k to avoid discrimination testing. Add profit sharing if you want flexibility. If you are a high earner and your employees do not drive up coverage costs excessively, you may still be able to add a Cash Balance plan, but the math requires careful modeling.

Summary of self-employed retirement plan options by contribution limit, Roth availability, and administrative complexity.

Plan2026 Max ContributionRoth AvailableLoans AvailableAnnual Filing Required
SEP IRAUp to $72,000 (25% of net income)Technically yes (SECURE 2.0), but few custodians supportNoForm 5500-EZ if assets exceed $250K
SIMPLE IRA$17,000 deferral + 2-3% matchNoNoNo
Solo 401kUp to $72,000 ($80,000+ with catch-up)Yes (Roth deferrals)Yes (up to 50% of balance)Form 5500-EZ if assets exceed $250K
Safe Harbor 401kUp to $72,000 + required employer contributionYesYesForm 5500 annually
Cash Balance / DB$100,000 to $300,000+ (age-dependent)No (but can roll to Roth IRA later)NoActuarial report and Form 5500 annually
Source: IRS Publication 560 and Section 415 limits for 2026
Contribution limits assume sufficient earned income. Actual limits depend on individual compensation and plan design.

Deadlines and setup logistics

Timing matters. A Solo 401k plan document must be adopted by December 31 of the tax year you want to make contributions for. Contributions themselves can be made until your tax-filing deadline including extensions, typically October 15 for calendar-year filers. If you miss the December 31 deadline, you can still open a SEP IRA for that year, since SEPs can be established as late as your filing deadline.

A Cash Balance plan also requires adoption by December 31 of the first plan year. Unlike a Solo 401k, you cannot establish one retroactively. If you realize in April that you should have started a Cash Balance plan, you have to wait until the following year.

Choosing a custodian. Most major brokerages offer Solo 401k plans with no account fees. Look for a plan document that permits Roth deferrals and, if you want the mega-backdoor Roth option, after-tax contributions with in-plan conversions. Not all custodian documents include this language. Read the plan document before signing.

Cash Balance administration. A Cash Balance plan requires an actuary to calculate contributions annually and a third-party administrator to file the Form 5500. Expect to pay $1,500 to $3,000 per year for a solo plan. The cost rises with complexity and the number of participants.

Coordinating multiple plans. If you have both a Solo 401k and a Cash Balance plan, contributions are made separately to each plan. The elective deferral limit applies across all 401k plans you participate in, so if you also have a W-2 job with a 401k, your total deferrals cannot exceed $24,500 in 2026. Employer contributions to each plan are calculated independently.

Common mistakes that cost self-employed owners money

The most expensive mistake is inertia. Many self-employed owners open a SEP IRA because it is easy, then never revisit the decision as their income grows. By the time they realize a Solo 401k or Cash Balance plan would serve them better, they have left years of deductions on the table.

Undercontributing to a Solo 401k. The employee deferral component is often overlooked. Some owners treat a Solo 401k like a SEP and contribute only the employer profit-sharing portion. If your income supports it, contribute both the $24,500 deferral and the profit-sharing component to reach the $72,000 ceiling.

Missing the December 31 adoption deadline. A Solo 401k cannot be established retroactively. If you realize in March that you want a Solo 401k for the prior tax year, you are out of luck. A SEP IRA can be opened by the filing deadline, but you lose the Roth and loan features.

Ignoring S-corp salary optimization. For S-corp owners, the salary you pay yourself determines your contribution capacity. A salary that is too low limits how much you can contribute. A salary that is too high increases payroll tax without a corresponding contribution benefit. Model the tradeoff to find the salary that maximizes after-tax wealth.

Failing to coordinate multiple plans. If you have multiple businesses or a side gig on top of a W-2 job, contributions across all plans must stay within the aggregate limits. The elective deferral limit applies to you as an individual, not per plan. Exceeding the limit triggers excess deferral rules and potential penalties.

Ready to model the right plan combination for your income and goals?Talk to an advisor

A fiduciary can design the plan mix that maximizes your deduction.

InverseWealth is a fee-only RIA that helps self-employed professionals and business owners choose among SEP IRA, Solo 401k, Cash Balance, and other vehicles based on your actual income and goals. No commissions, no product sales.

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FAQ

Frequently asked questions.

How much can I contribute to a Solo 401k in 2026?

In 2026 you can contribute up to $24,500 as an employee deferral, or $32,500 if you are 50 or older. The new SECURE 2.0 super catch-up raises the deferral to $35,750 for participants aged 60 to 63. On top of that, you can add an employer profit-sharing contribution of up to 25 percent of net self-employment income. The combined limit is $72,000, or $80,000 with the standard catch-up. Your actual maximum depends on your net earnings after deducting half of self-employment tax and the contribution itself.

What is the difference between a SEP IRA and a Solo 401k?

Both plans allow contributions up to $72,000 in 2026, but they differ in structure. A SEP IRA accepts only employer contributions calculated as a percentage of net income. A Solo 401k accepts both employee deferrals and employer profit-sharing contributions, which lets lower earners shelter more. The Solo 401k also offers Roth elective deferrals, participant loans, and mega-backdoor Roth conversions that SEP IRAs do not support. If your income is modest or you want these features, the Solo 401k is the better choice.

Can I have both a SEP IRA and a Solo 401k?

Yes, but your combined contributions across all plans are subject to the Section 415(c) annual addition limit of $72,000 in 2026. Maintaining both plans adds administrative complexity without increasing your total contribution capacity. Most self-employed owners choose one or the other. If you want features the SEP lacks, such as Roth deferrals or participant loans, switch to a Solo 401k rather than running both plans simultaneously.

What is a Cash Balance plan and who should use one?

A Cash Balance plan is a defined benefit plan that expresses your retirement benefit as a hypothetical account balance rather than a monthly pension. Contributions are calculated by an actuary based on your age, target benefit, and assumed investment returns. The older you are, the more you can contribute. Cash Balance plans are best suited for self-employed professionals over 45 who want to shelter $100,000 or more per year and are willing to fund the plan consistently for at least five to ten years.

How does S-corp status affect my retirement contributions?

An S-corp owner must pay a reasonable salary before taking distributions. That W-2 salary, not total business income, determines how much you can contribute to a 401k or SEP IRA. A higher salary increases contribution capacity but also increases payroll taxes. The optimal salary balances contribution headroom against payroll-tax cost. A fee-only advisor can model the tradeoff and find the salary level that maximizes your after-tax wealth while staying within IRS reasonableness guidelines.

What is the deadline to set up and fund a Solo 401k?

The plan document must be adopted by December 31 of the tax year you want to make contributions for. Contributions themselves can be made until your tax-filing deadline including extensions, typically October 15 for calendar-year filers. If you miss the December 31 adoption deadline, you can still open a SEP IRA for that year since SEPs can be established as late as your filing deadline. However, you will lose the Roth deferral and loan features that a Solo 401k provides.

Can I make Roth contributions to a SEP IRA?

Starting in 2023, the SECURE 2.0 Act permits employers to offer Roth SEP IRA contributions. However, most custodians have not yet updated their platforms to support Roth SEPs as of 2026. If Roth contributions are a priority today, a Solo 401k is the more practical choice because Roth elective deferrals have been available in 401k plans for years and are widely supported by major custodians.

How do I choose between a SIMPLE IRA and a SEP IRA?

A SIMPLE IRA has a lower contribution ceiling of $17,000 in employee deferrals plus a 2 or 3 percent employer match, but it allows employee contributions and is designed for businesses with up to 100 employees. A SEP IRA has a higher ceiling of up to $72,000 but accepts only employer contributions. If you are a solo owner with no employees, the SEP usually wins on contribution capacity. If you have a small staff and want employees to contribute their own money, the SIMPLE may be simpler to administer.

Sources
Footnotes
  1. 1. The Section 415(c) annual addition limit for defined contribution plans is $72,000 in 2026 per IRS Notice 2025-67.
  2. 2. The Section 415(b) maximum annual benefit for defined benefit plans is $290,000 in 2026 per IRS Notice 2025-67.
  3. 3. The 401(k) elective deferral limit is $24,500 in 2026, with a $8,000 catch-up for those 50 or older, per IRS Notice 2025-67.
  4. 4. The SIMPLE IRA employee deferral limit is $17,000 in 2026, with a $4,000 catch-up for those 50 or older, per IRS Notice 2025-67.

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