529 to Roth Rollover Question

I know there are several qualifications for being able to roll funds from a 529 to a Roth. My specific question is regarding the earned income requirement. As I understand, the beneficiary would have to be eligible to contribute to a Roth IRA for the given year (earned income up to $7k), but does the income limit (the same income limit that applies to contribution eligibility) still apply?



Yes, it’s the same earned income which could have otherwise been used for a regular Roth IRA contribution if not used instead to qualify for the 529 rollover.



But in order to make a Roth contribution, there’s an amount of income that eliminates your ability to make the contribution. For example, if filing MFJ, you cannot make a Roth contribution if your MAGI is over $239,999. My question is whether that income limit still applies when doing the 529 to Roth rollover. I read somewhere that the beneficiary can have unlimited income and still be eligible, as long as they have earned income up to the rollover amount.



It’s correct that there is no upper income limit, so a high income 529 beneficiary will be eligible for the rollover(s) from the 529.



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