recharacterization after changing trustees

Client did a conversion to his Roth in 2017. He then transferred both IRAs to a new trustee in 2018. He now wants to recharacterize a portion of the converted amount.

What options does he have if the prior trustee cannot/will not provide the value of the IRA at the time of conversion so that the NIA can be calculated?



The options are controlled by the new custodian’s procedures for determining a reasonably accurate “opening account value” from which to determine the NIA. Some custodians just use the value of the account when they received it, others may be agreeable to having the client submit a month end statement from the prior custodian for the month end of the month the contribution was being made. Client should try to determine the opening balance himself because it may affect whether he even wants to recharacterize. If the gains are large on his conversion, the effective tax rate he is paying drops which makes the conversion more attractive to retain. Otherwise client is transferring potentially tax free gains back to a TIRA account. Once client determines if he still wants to do a partial recharacterization, then he needs to discuss what figure the new custodian will use as their opening balance. Of course, any compromises made are either beneficial or damaging to the client since they affect the amount of Roth dollars going back to the TIRA.

Would the 1099-R for the conversion or the 5498 be of help here?

Yes, it would be conclusive IF the conversion was done to a Roth IRA with no current balance. But since the opening balance must include the entire Roth balance immediately after the conversion, the 1099R/5498 would not be useful if the Roth already had a balance before the conversion was done.

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