Adjusted Opening and Closing Balance With Recharacterization

Q.1: Vanguard determines the value of its IRA accounts at the close of business each day. A Roth conversion of part of a traditional IRA took place there on 12/11/2007. Does the “adjusted opening balance” =
a. The sum of the Dec. 11 Roth IRA value + the conversion value? Or,
b. The Dec. 12 Roth IRA value (which includes the conversion value)?

Q. 2: If some of the conversion is recharacterized on 4/9/08, does the “adjusted closing balance” = the Roth IRA value on April 8 (the day before the recharacterized amount is returned to the traditional IRA)?

Thank you.



Q 1: When the custodian determines these values, the Regs appear flexible enough to conform to the administrative procedures of the particular custodian. Therefore, if Vanguard values IRA assets at the close of business, they are most likely using the opening balance on the close of the day of conversion that includes the converted amount, ie. 12/11. It also seems incumbent on the custodians to use the same approach in determining the closing value so that the valuation period is consistent between opening and closing. The most relevant Regulation is copied here:
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“(3) When an IRA asset is not normally valued on a daily basis, the fair market value of the asset at the beginning of the computation period is deemed to be the most recent, regularly determined, fair market value of the asset, determined as of a date that coincides with or precedes the first day of the computation period. In addition, solely for purposes of this paragraph (c), notwithstanding A–3 of this section, recharacterized contributions are taken into account for the period they are actually held in a particular IRA.”
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With today’s complex investments, it is quite possible for an IRA account to hold assets valued on a weekly, daily, or real time basis, and the copy above seems primarily concerned with those assets valued less frequently than daily. It does not appear that real time values within a trading day are going to be considered.

Q2: In view of the above, yes, probably the close of business on 4/8 for the adjusted closing value.

In those cases where the IRA custodian will not calculate the earnings and leaves it to the taxpayer, the taxpayer would use the worksheet on p 31 of Pub 590. Lines 2 and 3 could in theory incorporate valuation of individual assets on a more refined basis than above, but it certainly does not appear to me to be worth the trouble.

Alan, thank you.

Sorry to say but I just noticed my typo in the conversion date which was actually 12/12/08. Since your answer used the same date as the conversion, I assume that the 12/12/08 Roth IRA balance should in fact be the correct adjusted opening balance. You also said the Regs appear flexible enough to conform to the administrative procedures of the particular custodian, so I will just go with what Vanguard does, whether the 12/11 balance + conversion amount or the 12/12 balance which includes conversion amount.

Thanks again.

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