QLACs and Roth Conversions

While we know that Qualifying Longevity Annuity Contracts are excluded from RMD calculations, must they be included in the year-end fair market value for purposes of calculating the taxable/nontaxable portions of a Roth conversion? Having trouble finding guidance on this.

Thanks,

Robert



Very good question and there is no direct guidance. The IRS has a habit of overlooking basic reporting requirements when they issue Regs and IRS Pubs, including the recent QLAC Regs.   In a broader context, the IRS has not clarified how the year end FMV of any annuitized IRA is to be reported. As an IRA owner, if I am not provided with a 5498 or similar report of FMV as of 12/31, I would  ignore the contract and not attempt to use any imprecise amount such as the contract price, present value calculation etc to complete an 8606. If the insurer does provide a FMV, it should be used.  However, note that the QLAC Regs DO specify that the FMV of the contract is to be reported to the IRA and IRA owner every year, therefore the IRA owner will have a value for the contract to include with the other IRAs for use in completing Form 8606. I do not know whether FMVs are reported by insurers of other annuitized IRAs post annuitization, but for those as well, the IRA owner should apply the report if it is provided. 



Thanks Alan. Hopefully we will get some clarification at some point.  



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