RMD and Roth Recharacterization

Situation: RMD is required for 2024; first one, age 73 this year. Person did a Roth conversion (from Traditional IRA to a new Roth IRA) thinking this would count as RMD. Person has now learned that a Roth conversion does not count as RMD. Wants to fix things. :slight_smile:

It appears that the Roth Conversion needs to be recharacterized, so that it is “undone”. This is at Vanguard. The online form to accomplish that allows the recharacterized amount to go to a nonretirement fund or as a check to individual. This amount will be taxable income for 2024, with taxes to be paid as estimated taxes this quarter.

Questions - besides advice to research before taking action. :slight_smile:

Is recharacterization necessary (just confirming)?

Does it make sense that it is not possible to have the funds returned to the Traditional IRA? So that an RMD can then be taken after that.

If the funds are removed from the Roth IRA and moved to a nonretirement account, will the IRS view that as meeting the requirements for this year’s RMD?

Any other thoughts/advice?

Thank you!

Replying to myself here after some further reading.

It appears that the Roth IRA conversion has led to:

A withdrawal from the Traditional IRA, which is taxable and counts towards any RMD.

An “excess” Roth IRA contribution that needs to be withdrawn (not recharacterized). Any Roth IRA income earned is taxable (as if it were in a taxable account). That withdrawal goes to a nonretirement account.

This now makes sense, since in the end it matches what would have happened if a simple withdrawal from the Traditional IRA had occurred. But I would appreciate any confirmation (or clarification).

Thank you.

Sorry, that’s not possible any longer. Roth conversions can no longer be recharacterized since the TCJA.

No. The way to fix this is to take out the RMD amount that’s required.

No, that would be against the law.

AJ

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Not correct. The conversion does not count toward the RMD, since RMDs are not allowed to be converted.

No, the conversion was done. It was not an excess contribution - it was a conversion. It stands on it’s own as a conversion to a Roth IRA. It can be withdrawn, and if the owner of the IRA has had a Roth IRA open and funded for at least 5 tax years, it will be a qualifying contribution. If the owner of the IRA has not had a Roth IRA open and funded for at least 5 tax years, the conversion amount can be withdrawn without taxes or penalties, but any earnings withdrawn would be subject to taxes and penalties. In this case, because the IRA owner is over 59 1/2, penalties would not apply to the earnings, but taxes will still apply.

Sorry, you have an incorrect understanding.

Yes, what should have happened was that the RMD amount should have been taken directly out of the T-IRA. Since, instead, a conversion was done, and conversions cannot be undone, an RMD still needs to be taken out of the T-IRA. So the owner of the T-IRA will effectively end up paying taxes on 2 times the amount of the RMD.

AJ

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aj485,

Thank you for the reply! It seems the person involved may have to take two distributions this year. :frowning: I may have some more questions on that later.

I think I can guess what the tax reporting for this first set of events will be, but wonder if you’d be willing to confirm (or again, clarify) …

For the (incorrect) Roth Conversion from the Traditional IRA, I think a 1099-R will be issued, with Box 7 having a first code of “7” (Normal Distribution) and both Box 1 (Gross Distribution) and Box 2a (Taxable Amount) showing the amount converted. I’m guessing Box 2b will have neither box checked (“Taxable Amount Not Determined” and “Total Distribution”).

For the correction of the amount converted to the Roth IRA, where the original converted amount and any earnings are withdrawn and transferred to a nonretirement account, I think a 1099-R will be issued, with Box 7 having a code of “8”. I’m guessing that the Box 1 Gross Distribution will show the total amount withdrawn (original conversion amount and any earnings) and the Box 2a Taxable Amount will be the earnings component. Box 2b will hopefully have the first box NOT checked, and will most likely have “Total Distribution” checked since this Roth IRA was just opened for this one event and will now be empty.

Does that sound right?

I assume a second withdrawal from the Traditional IRA will either be included in one 1099-R (with the amount above and this amount) with Box 7 showing “7”, or maybe there’s a second 1099-R just for this withdrawal.

Thanks again.

Well, since they haven’t yet taken their RMD, but this is the year they turned 73, they would have the option of leaving it until April 1, 2025 to take their 2024 RMD, and then also take their 2025 RMD by Dec 31, 2025. But, at some point, it appears as though they would have to take 2 distributions in a single year.

Why would they do this? Why not just leave it in the Roth account? They obviously didn’t need the money for living expenses, because they did a conversion, rather than have the RMD amount deposited into their checking account. So why is there a need to take the money out of the Roth account?

Are you sure that they actually did a conversion, where money moved directly from the T-IRA to the Roth IRA, with no stops in between? Or did they deposit the T-IRA money into a taxable account, and then do a contribution to a Roth IRA? Because if that’s the case, then they did not do a conversion, they did an excess contribution to a Roth IRA. That’s a whole different issue and it would have to be corrected. But that’s a different issue than you asked about before. On the other hand, the distribution from the T-IRA would count toward the RMD if they had the T-IRA distribution deposited to a taxable account first. So first, you need to understand if they actually did a conversion, like you initially said, or if they made excess contributions.

What needs to be done, and what tax documents will result depends on the answer to the question of whether they actually did a conversion or they made an excess Roth IRA contribution.

If there was a direct to Roth conversion of the RMD amount from the T-IRA done, then the person still needs to do an RMD out of their T-IRA. If they do it in 2024, then their 1099-R from their T-IRA will show the total distribution of 2 times their RMD amount with a code 7 in box 7, and the total amount taxable. The conversion to a Roth account for 1 RMD amount would be documented on their 5498, and they would also have to document the conversion on their tax return on a Form 8606. If they wait until 2025, then they would need to take both a 2024 and a 2025 RMD, before doing any conversions. Their 2025 1099-R would show the totals of those distributions, with a Box 7 code of 7.

Since, if they did the direct T-IRA to Roth conversion, they should not be doing anything to the Roth account, there should be no 1099-R for the Roth account. If they do take money out of the Roth account, the tax documents would depend on how long the owner has had any Roth IRA open and funded.

If they didn’t do a direct T-IRA to Roth conversion, and instead deposited the money to their taxable account and made a Roth contribution, then what needs to be done depends on if they (or their spouse, if married) had earned income that was within the bands for Roth contributions.

I don’t think it’s really helpful to be asking questions on behalf of someone else, because there is more information needed, and I find that, just like the old game of telephone, the answers to questions get changed when they go through someone else. So if you really want to help this person, you should have them come on here and ask their own questions.

AJ

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Hmmm, could they take half the 2024 RMD in Dec 2024 and then half the 2024 RMD in April 2025 and then the 2025 RMD in Dec 2025? That way they might reduce the tax hit somewhat by taking roughly 1 1/2 x RMD in 2024 and 1 1/2 x RMD in 2025. Then they can go back to normal in 2026 and take the regular 2026 RMD.

aj485,

Thanks for the reply - sorry if I’m causing frustration. :frowning: First, a friend asked me to help, so I’m doing what I can. Second, this was a Traditional IRA to Roth conversion (direct, Vanguard to Vanguard), and was the first (and so far only) withdrawal of any sort from the Traditional IRA this year (or any year).

In reading some other sources, and perhaps none of them are as reliable as your advice, I’m seeing a consistent theme.

First, there is a “first-dollar-out” type of rule in removing funds from a Traditional IRA. If an RMD is required in a year, then the first dollars out are part of that required RMD.

Second, any RMD dollars removed from a Traditional IRA are not eligible for rollover. For example, to a Roth IRA.

Third, if a rollover/conversion is made with these first dollars out of the Traditional IRA, this is an ineligible rollover/conversion, but these first dollars will be treated as part of the RMD. Which is why there is the rule to do the full RMD directly to a nonretirement account before doing any desired Roth IRA conversions.

Someone referred to a Q&A in the CFR that describes some of the above in IRS regulatory language. The link and the relevant part of the Q&A are below.


Q-7: When is a distribution from a plan a required minimum distribution under section 401(a)(9)?

A-7: (a) General rule. Except as provided in paragraphs (b) and (c) of this Q&A, if a minimum distribution is required for a calendar year, the amounts distributed during that calendar year are treated as required minimum distributions under section 401(a)(9), to the extent that the total required minimum distribution under section 401(a)(9) for the calendar year has not been satisfied. Accordingly, these amounts are not eligible rollover distributions. For example, if an employee is required under section 401(a)(9) to receive a required minimum distribution for a calendar year of $5,000 and the employee receives a total of $7,200 in that year, the first $5,000 distributed will be treated as the required minimum distribution and will not be an eligible rollover distribution and the remaining $2,200 will be an eligible rollover distribution if it otherwise qualifies. …


So, in the situation I’ve described, your suggestion to leave the converted funds in the Roth IRA confuses me. Everything seems to say that this is an ineligible rollover that cannot remain in the Roth IRA, since. these “first dollars out” are treated as part of the RMD.

Several sources say the steps to fix the situation include treating this as an excess contribution to the Roth IRA (even though it was a conversion), and this excess contributon and any earnings can be removed, with the earnings reported as taxable.

I wanted to see how Vanguard would view/proces this, so I did a pretend “removal of excess contributions” from my Vanguard Roth IRA (without completing!) just to see what type of information and instructions there were. The two relevant questions/possible responses were: I could specify my request was to: “Remove a contribution from the account as an excess contribution.” It then asked for “the source of the excess to be removed”, and “Conversion” was one of the options (and seems appropriate here). I recognize that Vanguard isn’t providing tax advice, but it seems this process recognizes that the conversion can be viewed as an excess contribution.

I hope you understand why I’m confused, with your advice differing from other sources. Just trying to help fix this with the least pain. I’ll understand if you choose not to continue this discussion, but I would like to hear your thoughts.

Thanks.

As far as I am aware, RMDs are calculated based on calendar years only. I’m not aware of any way to defer part of the RMD.

AJ

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I’m not sure why that would have been allowed without some type of warning to the friend, since Vanguard should have been aware that the individual was turning 73 in 2024, which would require an RMD. Was the friend asked whether they were deferring their first RMD distribution until 2025 during the conversion process? If not, then, again, I’m not sure why Vanguard would have allowed this.

I would counter back with the argument that because your friend is turning 73 this year (2024), they do have the choice to defer their first RMD until as late as April 1, 2025 - so the first dollars out of the IRA wouldn’t necessarily have to be the RMD. Which means that they can still take their RMD distribution - either this year or next year, without having to remove excess contributions from the Roth IRA.

That’s why I asked if Vanguard questioned your friend about deferring the conversion because they hadn’t taken their RMD. Because the only way that I would see Vanguard allowing your friend to do a conversion would be if your friend told them they were deferring the RMD.

AJ

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aj485 said: “Because the only way that I would see Vanguard allowing your friend to do a conversion would be if your friend told them they were deferring the RMD.”

Don’t know what warnings Vanguard provided. If there were some they were clearly ignored, and Vanguard allowed the conversion to occur.

But I assume any brokerage recognizes it doesn’t know what else the customer has withdrawm from other Traditional IRAs they may have elsewhere. I.e., the RMD could have been met via a withdrawal from Brokerage XYZ first, thus making this Vamguard conversion OK. That didn’t happen in this case, but I would guess any brokerage assumes their customer is responsible for making sure the withdrawal/conversion is done correctly. Obviously that didn’t happen here. :-{

Since the conversion occurred in this calendar year, it still appears to me that the dollars in the Roth IRA are an ineligible rollover and need to be removed. And that the RMD has been met via the withdrawal from the Traditional IRA that occurred in the form of the rollover to the Roth IRA, since these “first dollars out” are treated as part of the RMD.

I understand you disagree, thus my confusion. Do you have any citations that would help me understand your thoughts (keep the rollover in the Roth IRA; do another Traditional IRA withdrawal to meet the RMD)?

Thanks.

Did Vanguard ask your friend if their RMD requirement had already been satisfied? While brokerages may not know about RMDs being taken from other accounts, they do have a duty to not allow improper conversions. So that means that in and after the year that RMDs begin for a customer, they need to understand that the RMD has already been taken out before they allow a conversion to take place. But since the first year RMD can be deferred, they should also allow exceptions to having to take the RMD out.

Since the required beginning date can be deferred in the year that someone reaches the age that RMDs are required, the beginning date for the initial RMD can be as late April 1 of the year after turning 73. From IRS Pub 590-B:

Look, if you think that your friend has to take out the conversion and the earnings as excess contributions, that should be your advice to your friend. They will pay taxes on the earnings, and the earnings need to be calculated on the total IRA balance during the time that the excess contribution was in. As an example, the friend made an excess contribution by converting $37,736 (the RMD on a $1MM account balance for someone turning 73 this year) into a Roth IRA that already had a balance of $462, 264, so the balance on the account as of the date that the conversion was added was $500,000 The friend never got around to investing the converted amount, so the conversion stayed in a money market fund for 6 months until the friend figured out that they had made a mistake, and earned $943. However, the rest of the account was invested in stocks that had a total return of $49,057 during that timeframe, so the total balance on the account on the day that the friend takes out the earnings is $550,000, or a 10% increase. That means that the friend has to take out $3,774 (10% rounded to the nearest dollar) in earnings, not the $943 that actual conversion earned.

AJ

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I don’t quite understand RMDs in that case. For example, can’t the RMD be taken monthly? Let’s say end of year 2023 balance is $1,000,000 and RMD required is $37,736 and has to be withdrawn for 2024.

Case I: Can you withdraw $3,144.67 ($37,736 / 12) each month from Jan 2024 to Dec 2024?

Case II: (first year of RMDs only): Can you withdraw $3,144.67 each month from April 2024 through March 2025?

Case III: (first year of RMDs only): Can you withdraw $18,868 in 2024 and $18,868 in 2025 before April (for a total 2024 RMD of $37,736)?

You can take them monthly, weekly, daily or hourly. The law, however, requires that the total required be taken within a calendar year, and can not be put off until the next year.

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Sure you can take it monthly. Then you add up all the months from Jan - Dec. You just can’t add in prior year monthly withdrawals or future year monthly withdrawals to meet RMD requirements for a particular year.

Yes, that would meet the 2024 RMD requirement.

No. Taxes are done on a yearly basis. Case II has distributions of $25,157 in 2024 and $12,579 in 2025. Case III has distributions of $18,868 in each 2024 and 2025. Neither meets the initial 2024 requirement of $37,736 or the deferred 2025 requirement of $37,736.

Edited to add: If Case II distributions occurred on a day other than the first calendar day of each month, Case II distributions for the deferred 2025 RMD would only be $9,434 and $3,145 would count toward the 2025 regular RMD requirement. It still doesn’t meet the 2025 deferred RMD requirement.

AJ

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That’s what I’ve been doing since I turned 70 (or whatever the age was back then). Works good for me.

It appears that I have misunderstood what you wrote here initially. I understand it as they can “leave it” in the IRA account “until April 1, 2025” and then “take their 2024 RMD” in April. Obviously that isn’t what you meant. Can you explain what this statement means?

Actually it is mostly what I meant. For the first RMD, you have until April 1 of the year after you reach your RMD age (currently 73) to take it - so not anytime “in April” - it has to be taken no later than April 1. Since @downtownmaggie’s friend turned 73 in 2024, they must take their RMD for 2024 no later than April 1, 2025. They still have a requirement to take their 2025 RMD by Dec 31, 2025, so if they wait until 2025 to take their 2024 RMD, they will be required to take 2 RMDs in 2025. Please read the excerpt from IRS Pub 590-B that I posted above.

AJ

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So back to my original 3 cases, can they take some of the 2024 RMD in 2024, and some of their 2024 RMD in 2025 before April 1, 2025? Let’s say they take half their 2024 RMD in Dec 2024, and the other half in Jan 2025. And then they take their 2025 RMD in Dec 2025. That results in half an RMD worth of income taken in 2024, and one and a half of an RMD worth of income in 2025. This could potentially be beneficial if someone needs their 2024 AGI to be below a certain level, but are willing to have a higher AGI in 2025.

NOTE: Case II was stated incorrectly (off by a month I think), I’ll go edit it now.

Or am I totally misunderstanding, and the IRS considers a 2024 RMD taken in Jan-Mar 2025 to be CY 2024 income???

Again, NO!!! The full RMD must be taken during a single calendar year. I don’t know how many more ways to explain this.

If you turn 73 in 2024, you can either take your full 2024 RMD during 2024 or take your full 2024 RMD between Jan 1, 2025 and April 1, 2025. You cannot split it over 2 different calendar years.

You still have an obligation to take your full 2025 RMD between Jan 1, 2025 and Dec 31, 2025.

No, it’s 2025 income because it was taken in 2025.

Go back and look at my explanation of your cases. It explains why your theory of splitting RMDs does not work.

AJ

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