One check, two IRAs
I have a client that rolled over her 401(k) to her IRA and Roth IRA. She had a small amount of after-tax contributions that we specified be rolled to her Roth IRA, with the balance going to her IRA. The TPA sent one check, but specified the after-tax cost basis on the distribution statement. Can we deposit the funds to the IRA and move the small after-tax amount to the Roth (with supporting documentation), or are we going to need to have the TPA cut two separate checks (which will be a small annoyance to the client)?
Permalink Submitted by Alan - IRA critic on Wed, 2018-05-23 16:52
These split rollovers under Notice 2014-54 should always be done with two checks, one made to “IRA FBO (client)” for the pre tax amount and the other made out to “Roth IRA FBO (client)” for the after tax amounts. If client had a Roth 401k balance AND after tax contributions to a separate sub account), then there should be 3 checks. And there should be a 1099R for each check issued. Assuming there was NO Roth 401k balance, receiving one check likely means there will also be only one 1099R, and some tax programs cannot handle a single entry when the funds go into two different IRA types. The tax entry problem can usually be solved by entering the single 1099R as if it were two forms, one for each IRA, but Box 2a and Box 5 need to be completed correctly. The more serious and immediate exposure here is that the IRA custodian could mess up the contributions and that is very difficult to correct. All in all, it would be better to have the TPA re issue as two checks as indicated. Another very workable option if the TPA prefers is to issue a direct rollover check for the pre tax amount to the TIRA, and issue a check for the after tax amount payable to client, who can then do a 60 day rollover to her Roth IRA. That eliminates the risk of the new custodians mis applying the split contribution. I imagine the check just issued is simply payable to “IRA FBO Client” or similar. Not good if “Roth” is not mentioned, since after tax contributions can be rolled to a TIRA, and if they are client will be stuck with Form 8606 for life and taxable conversions are the only way to get IRA basis into a Roth. If TPA will not cooperate, then specific instructions that the IRA custodian cannot miss should be included, and the correct IRA deposits verified immediately.
Permalink Submitted by Josh Harmon on Wed, 2018-05-23 17:06
Thanks! If we take money out from an IRA (that has a cost basis) via Roth conversions or withdrawals, do gain and basis come out pro rata?
Permalink Submitted by Alan - IRA critic on Wed, 2018-05-23 18:00
Yes, as calculated on Form 8606.