Correcting excess conversion pre-RMD in 2018 (no rechar option)

I have read through the forums on this topic but would like to cross-check something my brokerage firm told me in terms of fixing a small mess I’ve created. I am over 70-1/2 and subject to RMDs, which is $25,000 for this year. Earlier this year, I converted $100,000 of my IRA to my Roth, but did so before taking the RMD. I now understand that was a no-no. Of course, the option to recharacterize back to an IRA is no longer an option. The brokerage firm has essentially recommended the following:

1. Remove $25,000 of my Roth (forgetting gains/losses for the moment) and have it done as a “removal of excess contribution.” They say this will essentially be equivalent to my having taken the RMD at the same time (I guess to be read as “prior to”) the conversion. I would remove this amount to my taxable account. As the account has gone done a bit since I’ve done the conversion, no additional tax to pay here. I gather this will generate a 1099-R, but with no tax cost implications. I don’t think there would be a form 5329 required since the removal of excess is happening in the same year as the excess contribution.

2. After that is completed, I could then convert another $25,000 to my Roth to reach my goal of converting $100,000 in total for the year. The 5498 for the Roth would then presumably show $125,000 (or would it be netted down to $100,000 because of the removal?)

After this is done, my net taxable position would be the same as if I had processed the $25,000 RMD first and then converted an additional $100,000 to my Roth.

Does this sound correct or should I be taking a different tack? I am hoping to not have to remove-as-excess all $100,000 of the converted amount this year, but rather, just the RMD amount.

Any input, advice, or suggestions greatly appreciated, and thank you in advance.



  1. When you converted 100k to Roth before taking the RMD, 25,000 of your conversion is treated as your RMD, so your RMD was completed. As the broker indicated, because RMDs are never eligible for rollover (conversion is a rollover), you have an excess 25,000 contribution to your Roth IRA. The broker is correct about requesting a corrective distribution from the Roth IRA including any earnings on that 25,000. The earnings distributed to you will be taxable in 2018. You are correct, no 5329 due to return of the 25,000 plus earnings. This is not costly at all, but is a processing hassle because your tax return will report the 25,000 as a taxable distribution, and only 75,000 converted on Form 8606. That means your return will not be consistent with the 1099R, so you will have to include an explanatory statement as to what happened.  You will also have to explain this to the Roth custodian to convince them to treat the 25,000 as an excess contribution.  Of course, you will also get a 1099R for the corrective distribution with only the earnings showing in Box 2a.
  2. You could do that, but will be taxed on 25,000 plus 100,000 = 125,000 for 2018 plus the small amount of earnings on the excess while it was in the Roth.  The 5498 will probably show 125,000 as a conversion contribution but will be incorrect, because you really only converted 100,000. You can cover this with your explanatory statement. Note that the 1099R and 5498 will not necessarily conform since they are issued by different custodians, and neither will conform with your return. But your statement should clarify things with the IRS. Yes, your net taxable position will end up the same as if you did it right, except for the tax on the small amount of earnings on the excess. 
  3. As indicated, this is not costly, but is a filing hassle plus you have to withdraw the excess amount.

Alan, Thank you very much for taking time to thoughtfully answer my question in such detail.  Sincerely appreciate your response, and the expertise you’re willing to share (along with the others who do so on this forum). Regards.

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