The $100,000 modified adjusted gross income (MAGI) limitation for converting a regular IRA to a Roth IRA or rolling a distribution over from a tax-qualified plan to a Roth IRA is eliminated beginning in 2010. Income from a conversion also can be deferred for two years if the conversion occurs in 2010. Many higher-income participants in tax-qualified plans are interested in taking advantage of this opportunity, but to do so they must take a distribution from the plan—there currently is no way to convert the benefit in place, even though tax-qualified defined contribution plans are now allowed to have Roth accounts within them. Some companies are considering allowing more in-service distributions to let participants take advantage of this opportunity. They must be careful, though, since this can raise plan liquidity, discrimination, and other legal and practical issues, and might not be permitted under a prototype plan document.