in the same arrangement. For purposes of this clause, the term employer shall include all employers treated as a single employer under subsection (b), (c), (m), or (o) of section 414. (iv) Automatic IRAs for non-employees The Secretary shall by regulation or other guidance provide for making available automatic IRAs to individuals who provide services that do not constitute employment. (D) Limits on contributions An employer shall not be treated as failing to satisfy the requirements of this section or any other provision of this title merely because— (i) aggregate payroll deduction contributions by or on behalf of an individual to individual retirement accounts of the individual exceed the deductible amount in effect under section 219(b)(5) (determined without regard to subparagraph (B) thereof) for any taxable year in which any payroll deduction contributions by the employer under an automatic IRA arrangement are made, or (ii) the employer chooses to limit the payroll deduction contributions under this subsection on behalf of an employee for any calendar year in a manner reasonably designed to avoid exceeding such deductible amount. (E) Default treatment as Roth IRA An employee on whose behalf payroll deduction contributions are made to an individual retirement account under subparagraph (A) may elect, at such time and in such manner and form as the Secretary may prescribe, whether to treat the individual retirement account as designated as a Roth IRA. If no such election is made, the account shall be treated as designated as a Roth IRA. (F) Deposits to individual retirement accounts of a designated trustee or issuer (i) In general An employer shall not be treated as failing to satisfy the requirements of this section, or any other provision of this title, merely because the employer makes all payroll deduction contributions on behalf of all employees (or all employees who do not specify an individual retirement account, trustee, or issuer to receive the contributions) to individual retirement accounts