RBD and Roth Conversions

If an indivdiual will turn age 70 1/2 in August 2011, their Required Beginning Date is April 1, 2012. What needs to happen with the 2011 RMD if that client converts their traditional IRA to a Roth in March 2011 (a year prior to their RBD)?

I have two trains of thought. The first is that a Roth conversion is reported similarly to a rollover, since RMD amounts are not rollover eligible, then the RMD must be distributed prior to the conversion. The second train of thought is to look at the regulations regarding an individual who dies prior to their RBD. If an individual dies prior to reaching their RBD, there is no RMD requirement…even if they die in the year that they otherwise would have been required to take an RMD.

So, how is the RMD treated? As being required for the 2011 year, and therefore must be distributed prior to conversion, or as not having been required since the account won’t exist when the client reaches their RBD?

I may be over thinking this so any help would be appreciated!



The regulations say that the first distribution in the year 70.5 is attained must be an RMD. A Roth convrersion cannot occur that year before the RMD. The April 1 of the next year rule does not control.



Add new comment

Log in or register to post comments