Recharacterization by death beneficiary?

Taxpayer converted TIRA to Roth in August 2010 and died in December.

In April 2011 non-spouse death beneficiary rolled Roth IRA to an inherited Roth IRA.

Can the original 2010 conversion still be recharacterized and if so is it by the Executor or the beneficiary?

Thanks



Yes, but not by the beneficiary alone. This may also be more difficult because of the transfer, particularly if the IRA custodian was changed from the decedent’s custodian.

If the custodian was changed, it may make things easier to transfer the inherited Roth back to the original custodian. But time is now critical with only 9 business days remaining to recharacterize a 2010 conversion, particularly with the added parties to the process for a decedent’s conversion.

The actual mechanics would take the inherited Roth and transfer it to an inherited TIRA, and custodians are not likely to be comfortable or experienced in completing the recharacterization transfers. See Q&A 6 (c) in the attached IRS Regs. Provide this reference to the custodian ASAP through the executor or administrator:

http://www.taxalmanac.org/index.php/Treasury_Regulations,_Subchapter_A,_



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