Beneficiary Recharacterization

Taxpayer makes Roth conversion in 2010 and then dies.

Beneficiary rolls over to inherited Roth IRA in early 2011.

Can 2010 conversion still be recharacterized and if so by whom?



The decedent’s executor, personal representative or the person responsible for filing the final income tax return can recharacterize the conversion up to the usual deadline. If the beneficiary is the surviving spouse who assumes ownership of the Roth, the IRS Regs are less clear, but I think the same option will apply.

Either way, if the beneficiary of the TIRA is different than the beneficiary of the Roth IRA, it could make for a very interesting court case, but it seems likely that the Roth beneficiary would inherit the funds anyway, but perhaps they would not be Roth funds.



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