The FAQs explain the structure of the new Roth 401(k) accounts in a 401(k) plan as well as the treatment of Roth contributions during discrimination testing and when withdrawn.
According to the FAQs Roth 401(k) contributions are to be treated the same as pre-tax nonelective contributions in 401(k) testing. In addition, the FAQs say Roth 401(k) accounts can be withdrawn on account of hardship if the plan allows hardships, but will require special attention for income tax purposes.
The IRS says the FAQs are for general information only and should not be cited as legal authority on any issues.
The FAQs are here .