aj485,
Thanks for the reply - sorry if I’m causing frustration. 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.