Wrap fee as misc investment expense deduction for IRA

Can wrap fees (on AUM) be deducted as an itemized deduction (investment expense) for an IRA account? Does it make a difference if the fee is deducted from the IRA or paid separately?



If the fee is billed to the person and not deducted from the IRA, it qualifies as a misc deduction subject to the 2% of AGI floor.



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